Policy SP14: Site BA1 - North of Baldock

PLEASE ACKNOWLEDGE RECEIPT OF THIS EMAIL

I am writing to submit my objection as a resident of the Parish of Bygrave to the Draft Local Plan, and the designation of Green Belt land to be allocated as housing sites within the Parish of Bygrave, to the north of Baldock.

I submit this objection on the basis that I do not think that the Local Plan has been objectively prepared, is justified, or effective and consistent with national policy.

It is appropriate that you should know that I am not a 'NIMBY', and fully understand and support the need for the country to have plans for future housing requirements. However the 'Updating the Overall Housing Needs' by ORS in 08/2016 document, states at;

para. 2 - that the 'projected increase in households across Stevenage and North Hertfordshire... based on rates from the 2012-based data and migration trends established using Mid-year Estimated data from the period 2005-15.

para. 6 - ..household projections are based on the ONS 2014-based SNPP, which are informed by migration trends from the 5-year period 2009-14. Future projections are particularly sensitive to the period on which migration trends are based, and PAS advise to Local Authorities suggests that the official projections are "VERY UNSTABLE". ...This viewed is echoed by academics and has been promoted by Planning Inspectors at numerous Local Planning Examinations.

Based on the above, I believe there should be greater 'push back' by NHDC in their Local Plan until numbers can be produced with greater clarity and certainty. Of greater importance is the fact that the EU Referendum has not been factored in to any of these projections, a situation which in the period up to 2031, could have dramatic implications both to the immigration numbers, to the number of EU citizens who currently live in the UK but who potentially could be forced to return to their home country, and to the economic situation of the UK (with its attendant housing implications). To use some of the wording of the North Hertfordshire Proposed Submission Local Planning Sustainability Appraisal Report under the heading of Nature of Effect, 'the loss of agricultural land is cumulative across the Plan area, of high probability, permanent and irreversible'. This Plan needs to be compiled on the basis of facts, which can be substantiated, not a wish list, based on guesstimates.

Turning to the North Hertfordshire Green Belt Review - July 2016, Table 2.2 'Green Belt Assessment Criteria' states that it is, "To preserve the setting and special character of historic towns" (Baldock is known as a 'Historic Market Town') Referring to the parcel of land marked 21 "Bygrave", it states that it "makes a Significant Contribution to restricting sprawl" and "Prevents urbanising influences". Figure 2.4 - "Contribution to checking the unrestricted sprawl of large built up areas", and Figure 2.6 "Contribution to Safeguarding the Countryside from Encroachment" both show parcel 21 "Bygrave" as making a SIGNIFICANT CONTRIBUTION.

Para. 49 states "The areas which contribute most to the purposes of the Green Belt are those around the periphery of, and between, the existing settlements of Hitchin, Letchworth and Baldock ... An additional factor in the assessment is the historic nature of the three Hertfordshire towns located within the Green Belt and their proximity to one another, resulting in increased sensitivity to development".

Page 125, "Green Belt Review Site Assessment - Baldock and East Letchworth" states that the whole site, designated this time as 200 representing the area north of Baldock, is shown as providing a SIGNIFICANT CONTRIBUTION TO GREEN BELT".

Page 134, Conversely at another site designated "West of Stevenage", this provides only a Moderate Contribution.

Para. 87, includes the statement "Stevenage Borough Council has removed an area from the Green Belt to the West of the A1(M)".

Para 93, states that "... consideration has been given to the need to identify safeguarded land for meeting development needs in the longer term. This function is met by the removal of the west Stevenage strategic site and employment land at Baldock from the Green Belt".

In this Green Belt Review, the Baldock sites have been identified as making a significant contribution to achieving the aim of a Green Belt. However the statement in para. 93 simply says that land at Baldock has been removed from that Green Belt. I can find no objective approach or basis for this action. Given that other sites have been identified as generating a lesser contribution to the Green Belt aims in this document, NHDC should be required to demonstrate why these sites have not taken precedent over the Baldock sites which make a greater contribution, since the approach they have taken is neither effective nor consistent with national policy.

The following now make reference to the National Planning Policy Framework (NPPF) 03/2012.

A part of the Ministerial prologue requires that "Sustainable development is about change for the better. ... This should be a collective enterprise. Yet in recent years, planning has tended to exclude, rather than include, people and communities. In part, this has been a result of targets being imposed, and decisions taken, by bodies remote from them. Dismantling this unaccountable region apparatus, and introducing neighbourhood planning, addresses this".

Para. 9 provides that "Pursuing sustainable development involves seeking positive improvements in ... the conditions in which people live, work, travel, and take leisure".

Para. 17 addresses "Core planning principles - a set of core land-use planning principles should underpin both plan-making and decision taking. The 12 principles include;
Bullet 1 - "be genuinely plan-lead, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area";
Bullet 5 - "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belt around them, recognising the intrinsic character and beauty of the countryside and supporting thriving communities within it";
Bullet 7 - "contribute to conserving and enhancing the natural environment and reducing pollution"; and
Bullet 11 - "actively manage patterns of growth and make the fullest possible use of public transport".

Para 28 requires "Supporting a prosperous rural economy. - Planning policies should support economic growth in rural areas, and should (bullet 2) promote the development and diversification of agricultural and other land-based rural businesses".

So taking the requirements of the NPPF, we need to have change for the better, not just change. The people of Baldock and Bygrave should be included and have notice taken of their views and wishes to shape the town and surrounding area, not to have been excluded, which is how I see the process of communication by NHDC at meetings has taken shape, with a tone of 'go away you little people, I have things to do my way'. Once again reference is made of the need to protecting the Green Belt, and also to promote agriculture, the activity currently undertaken on the land north of Baldock. Far too little attention has been paid to travel requirements, to determine whether the existing arrangements could cope with approx. 2,800 houses north of Baldock. Currently the Bygrave Road is totally unsuitable to take more traffic, there is no plan shown (and if there is one, why has it not been declared to the public) for a bridge or underpass over / under the railway to the south, which leaves any traffic wishing to go south into Baldock having to go under the railway bridge on the Great North Road, almost under the railway station. That section of road already suffers considerable and lengthy delays, and realistically, should not be considered an option should the north of Baldock site go ahead.

In summary, it feels as if the fact that Hertfordshire County Council own the land at the north of Baldock site, makes it an easy option for NHDC to choose this site as their Local Plan for 2015-31, and as a result they have not put together an object argument to justify this location, as opposed to others in the area, but which would not give them such an easy option. As stated above, once land has been built on, there is no going back. Greater consideration also needs to be given to the actual number of houses NEEDED, and if this means deferring a decision until substantive data is available, then that should be the appropriate action to take. Greater consideration should also be given to transport - one might assume a fair number of the people would need to commute by train. Rather than the plan saying that the platform at Baldock will be extended to take the extra commuters, the latest plan, recently released by the railway operator, shows that they actually plan to CUT the number of trains stopping at Baldock station. Likewise, how will people be able to drive into Baldock given that the existing road is already suffering major delays.

Finally I again submit that I am not a NIMBY, but it certainly is not equitable that a small historic market town, which is on the edge of a Green Belt, should be burdened with totally disproportionate to the size of the town, the largest number of houses for the NHDC Local Plan.

The plan should not be accepted in its present form, but overhauled to make it objective and proportionate across all towns in the area.

I shall be grateful if you will keep me informed of all developments in the matter.

See attached

I wish to make my objection to the Local Plan on the grounds that too much of the Green Belt seems to be in line to be built on. Baldock , it would appear, is to take the "lion's share" of the proposed building which is unacceptable. The infrastructure in the town is unsuited to the scale of housing proposed and local amenities are already stretched to breaking point. The addition of thousands more houses bringing with them more people for the GP surgery, children for the already over subscribed schools and more cars for the already congested roads will serve to destroy this historic market town. There must be an alternative to this Plan.

I urge those responsible to rethink these proposals.

I wish to object to the Local Plan as I consider it NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY. Policies SP8 and SP14 - The proposed allocation of 2,800 homes at North of Baldock (site BA1).

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

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

3. The local highways network will be severely affected by the development of this site. Almost all of the traffic wishing to pass through Baldock travels from the A1 to Buntingford and Stanstead along the A507, and from Cambridge and Royston towards London along the A505 (now redesignated B656), and these two roads cross at traffic lights at the north of Baldock at Station Road and Whitehorse Street. The two roads are offset and the traffic lights are slow because of three way lights and now pedestrian crossing time when requested, mainly at school rush hours. The crossroad is bounded by listed buildings which makes turning difficult especially for the huge lorries on the A507, some going left to Royston at that junction, which still go that way despite recommendations that they use the A1 and new bypass. One of the listed buildings has suffered many hits by vehicles. The proposed miniroundabout at Whitehorse St / Station Rd crossroads, the only mitigation planned for Baldock(AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction. The A507 passes the only access to the railway station causing extra congestion in peak travel periods. The railway access is shared by about 100 houses in a cul-de-sac Icknield Way East and work is currently in progress to build another 41 houses which will also have to use this access. The survey used to discuss traffic impact at this junction refers only to Icknield Way East, not Station Approach nor the A507 on to which they both deliver traffic. Station Road passes under the 14ft 6in railway bridge which historically has suffered frequent hits by lorries (8 or so per year). Despite the building of sacrificial metal beams at each side of the bridge and new signage the hits continue to occur. Whilst the long delay to rail traffic no longer happens, road traffic is still impacted while the mess is cleared up, the vehicle is extracted, two police vehicles are deployed. In addition to this there are numerous smaller holdups when lorries realise they will hit the bridge and manoeuvre via small residential roads damaging road furniture and grass verges as they do. The traffic on the A507 is constant and heavy especially in peak periods which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case. In the IDP the Traffic Baseline (para) shows that for North Herts as a whole traffic volume between 2014 - 31 is expected to increase by 16.1% and the average commuting distance in 2011 was 19.4km. Rail patronage at Baldock (para 5.12) went up 61% between 2005/6 to 2014/15. Para 5.19 mentions cycle paths in North Herts including Baldock but those referred to are mainly for leisure. Traffic demand in the A1 corridor may increase by 30% by 2031. No traffic surveys on the A507 have been carried out by NHDC for development of this Local Plan. It has not been included in any meaningful traffic modelling exercises during research and forward planning. GPS navigation also directs traffic along this road as an alternative to the A1/ Eastern bypass. All of this ensures that the A507 from the traffic lights to the A1 roundabout is not a suitable road to give access to a new development at BA1 as NHDC plans. It is very likely, since there are few work opportunities in Baldock that most of the residents will commute to other parts of North Herts, Bedfordshire and Cambridgeshire. NHDC has projected 2-3 vehicles per house so 5-7000 vehicles can be expected to be generated from this BA1 site and most will want to visit Baldock, Letchworth, Hitchin i.e pass through the traffic lights at Station Rd /Whitehorse St. The link roads proposed by NHDC will do nothing to solve this traffic problem. A "northern" link is proposed through the BA1 site and a "southern" link road is mentioned between BA 3 and BA4 but with even less substance. No information is provided as to route impact or viability. Indeed these roads threaten to conduct traffic of all descriptions through the new residential areas forming a real hazard to residents both by potential accidents and by air pollution. These roads are referred to in the Infrastructure Delivery Plan para 5.110 and it is stated they "have been included in the traffic modelling." But where is the evidence? Their "provision (cost and delivery) is assumed to be absorbed within the specific proposals for these areas and they are subsequently not specifically identified in this IDP." This and the fact that Baldock is listed as a separate town but in traffic terms is always grouped with Letchworth which has its own completely different transport problems is concerning, leading to the belief that Baldock traffic problems have not been acknowledged and addressed. The Plan is UNJUSTIFIED and NOT EFFECTIVE. There is insufficient evidence that the development can be achieved without a huge negative impact on the local highway network. This applies also in respect of BA4 and BA10 (SP8 and SP14). There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.

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


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

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

As the website link is not working I am emailing to lodge my objection to the proposed development of 2800 houses on land north of Baldock.

In my view, this will be an unmitigated disaster for the area, completely destroying the town of Baldock and putting unnecessary pressure on the local infrastructure in the town and surrounding villages.

This plan alone will almost double the size of the current population of Baldock with the addition of around 8000 more people and 5000 more cars. It will put undue pressure on the railway service which is already busy and which the operating company are looking to reduce by means of a slower service and fewer trains.
It would put undue pressure on roads, schools and infrastructure.

Some development to enable local people and their children to remain in the area is acceptable but placing the majority of the additional housing burden for the District on Baldock is both unfair and unnecessary. The requirement should be spread fairly across the whole District, which covers a large area.

Baldock is an historic town located in an area of historic importance in the town and local villages, with beautiful countryside which is home to a wide range of wildlife.

I am completely opposed to what would amount to a complete desecration of the town and local area.

I wish to put forward my views on why the plan is unsound; my legal understanding is insufficient to comment on the legality.
In particular, it is the large development of 2800 homes to the north of Baldock (site BA1) that concerns me.
The plan is UNSOUND because it allocates a disproportionate number of new homes to the smallest of the towns in North Herts, when few of the new population will have or obtain jobs in the town, but commute to Stevenage, Cambridge or London. There are few higher paid jobs in Baldock apart from the doctors and legal practices, whereas Stevenage is a major centre for growth industries such as aerospace and pharmaceuticals. Jobs of this type will not come to small industrial units of the type envisaged by the plan along the Cambridge road. The largest developments in Hertfordshire should be matched to the locations of employment growth, which are not in Baldock but in Stevenage and Welwyn Garden City.
The plan is UNSOUND because it greatly increases the size of the town without properly connecting it to the rest of Baldock. Proper connection was achieved with the development at Clothall Common, and placement of the Primary school between old and new portions of the town worked well to integrate the population. Access from Clothall Common by foot, car and bicycle is possible along a range of relatively short routes and none is congested. Despite this relatively good infrastructure connectivity and the rather smaller size of the development even there integration socially took some time.
The proposed site BA1 only touches the existing town at one end and extends much further from the town centre. It seems to be planned that it will have its own schools, leading to this new area being simultaneously part of Baldock and quite separate because children will not go to the same school. The railway will be a permanent barrier to movement, and the proposed link road will hardly help if it makes people first leave the town to the East before they start heading into the town past the already clogged junction of Station Road and Whitehorse Street. Many will take the shorter route, whether they are going into the town or to the adjacent parts of Letchworth, which generate car journeys for Baldock residents to visit Sainsbury and adjacent retail outlets, as well as the recycling centre.
The plan is UNSOUND because the infrastructure proposed will not work for the residents and making it work well would impose unacceptable costs. In fact the documentation presented acknowledges that there are significant unknowns even to do the minimum, associated with railway crossings and utility upgrades to allow Baldock's electrical, gas, water and sewage services to cope. (WYG Appraisal Report dated 11th November 2014)
It is impossible to increase the capacity of the key junction of Station Road and Whitehorse Street without demolishing the listed buildings surrounding it. Similarly, the railway bridge itself is already a problem for pedestrians with its narrow footpaths and for cyclists who are held up by the usual mixture of vehicles close to the kerb and vehicles close to the centre of the road. There is no room for a cycle lane. The junction for the station is complex and hazardous - I have myself been knocked off my bicycle by a vehicle whose driver just did not see me despite my high visibility yellow clothing and pulled out of the station approach as I was in front of her. The new pedestrian route crossing the railway would presumably deliver people to the top of the hill where Icknield Way meets the Royston road. This will not be a cycle friendly route into the town.
The proposed 'link road' is almost a bypass route through the new development and will be used by traffic heading East from the A1 northern junction. This type of link road (cf Biggleswade) will have numerous roundabouts and/or traffic calming and this will generate particulate emissions from the brakes and tyres of the vehicles using the route, even if they are powered electrically. A direct route from the A1 services to the Royston road roundabout with higher capacity would perhaps improve matters but it would be expensive and the 'internal' link road would still be needed to access BA1. However, it would allow heavy vehicles to be removed entirely from Station Road/North Road 'except for access'. The removal of heavy vehicles would require a new junction on the bypass allowing access from the bypass onto the Buntingford Road, but only for traffic from the Royston direction, and onto the bypass but only in the direction of Royston.
If development is imposed then these improved highway provisions should be imposed: direct trunk connection from the A1 services to the existing bypass and a new junction between Clothall Road and the existing bypass.
The plan is UNSOUND because the railway station is likely to remain of low capacity compared with Stevenage (large town, major interchange), Hitchin (moderate sized town and railway junction/interchange) and Letchworth (large town). If, as seems likely, the thousands of new homes are for people working in Stevenage, London or Cambridge then they should be in safe walking/cycling range of a high capacity railway station. Like most of the other considerations this suggests West of Stevenage as a better location, where multiple cycle routes cross the railway - and perhaps the Leisure Park should devote a little space from its car park to provide cycle racks.
In summary, the plan is UNSOUND because:
It provides housing disproportionate in quantity to the needs of Baldock.
It would lead to a new area that could not properly integrate with the existing town. (NPPF 23)
It will be neither a new centre with its own services and shops nor integrate with the historic town. (NPPF 23)
The infrastructure required to make it 'work' even with these problems is not likely to be provided. (NPPF 30, 124, 177)
Alternatives would place the housing close to where the work is; sustainable development must ensure that as far as possible people get to work on foot or by bicycle rather than placing additional loads on road and rail infrastructure. (NPPF 30)

One of the reasons that I believe that this plan has not been thought through thoroughly is that there is extremely limited parking in the railway station and in the roads nearby, with many of the roads full with not only the residents parking, but the many commuters. On the developers layout they plan to make Bygrave and Salisbury road two of the 3 roads out of the new development. Obviously the developers haven't actually seen the roads in person as especially Salisbury road is a very narrow road, which wouldn't be suitable for a further 2,800 Residents. This problem wouldn't be solved by putting in double yellow lines as this would make the parking problem even more worse than it is already and unless they widen the road, which will be very near impossible as the only way that they will be able to do that would be taking away the path. Also North road is already extremely busy, not only in the rush hours, but throughout the day, it rarely takes less than 15 minutes to get from Salisbury road to the traffic lights which is a mere 3 minute walk. This road will definitely not be able to cope with the increased traffic of at least 5000 cars on the road on a daily basis and resulting in a nightmare to use in all times of the day.
They should consider building a different route and not connecting it on to existing ones which aren't able to cope with the higher numbers of users. They could build a connecting road onto A505 from the North of Baldock, this will help to reduce the stress on the already stressed and overused roads.
Another point that I have to make which is similar to my previous point is that the infrastructure of the town is not designed for the proposed increased of the population on top of the present. Thus the services such as the doctors surgeries, are is already overrun - to make an appointment is usually a 2 week wait at least. The same problem is with the schools, for example Hartsfield has been oversubscribed for the last 4 years, if the development did take place this would put a huge amount of pressure on the 3 primary schools and only 1 high school. Especially as they plan to only build extra services once the houses have been built, by this time people will be moving in and their children will be needing to attend a school.
I want to know why Baldock is being forced to expand by 80%, almost doubling the size of it, while the other larger towns are only needing to expand by 10%. These larger towns will have the amenities to be able to cope with increased size of the population. They should have the roads and infrastructure to be able to withstand the higher pressures.
I hope that you consider my thoughts and ideas and take this into account when you are planning our future of our town.
Thank you for your time and please don't make any rash decisions.

Baldock is the oldest historical town in Hertfordshire which seems to be ignored.
In the last 30/40 years I have already seen Baldock double in size and is at risk of loosing its character.

The number of proposed homes is too excessive a proportion of Baldock and for the size of the town.

Baldock does not seem to receive the same consideration or support from Local Government as surrounding towns e.g. Hitchin or Letchworth.

With regard to this issue more credence should be given to Baldock Councillors who are considerably outnumbers within North Hertfordshire District Council.

Baldock already suffers from traffic congestion and would grind to a halt and die. The proposed plan does not take into consideration as to whether safe and suitable access to the site can be achieved by all people nor the pressure from traffic the number of homes proposed would have on the town.

The town centre and services would be overwhelmed by the additional population and the individually and character of the area lost.

I would like to express my support for the local plan to extend the provision of housing in and around Baldock.

I am satisfied that the plan takes into account and complies with relevant legislation and policy.

I am convinced that the expansion of housing in and around Baldock will be for the long term benefit of current and future residents of the area.

I am not persuaded by the arguments of opposers.

I am disappointed that the benefits of a potential economic and cultural boon associated with a London to Cambridge and Cambridge to Oxford axis have not been highlighted.

I hope that the decision makers in this case will stand up to the self serving, depressing, backward facing, small minded selfish arguments of the opposers.

I have tried to use the software but have not been successful. I am objecting to the proposed developments in Baldock on several grounds:
The number of houses and proposed locations are inappropriate and disproportionate for a small rural town. The houses on South Road and Clothall Road are too many. North of Baldock is a poor site to choose.
Rural nature of the town; Baldock is one of the oldest Roman towns in the country. When an house extension is proposed, archaeologists are involved. I do not see any provision on the plan for this. In the North of England, Roman heritage is supported. In Baldock the proposal is to build houses over the Roman areas.
Roads cannot cope at the moment with the increases in the A1 corridor. The railway bridge is crashed into frequently. The roads cannot cope. And the train services are about to be cut to a village service - there is no joined up thinking here.
Pollution will increase in this small town, increasing the childhood asthma rate.
The schools are all full now. There is no spare capacity, even short term. The one secondary school is huge and primary pupils are sent to outlying villages because there is no space in the town.
There are no proposed leisure facilities for sport. This is badly needed.

In summary, this development will destroy the rural nature of the town and it simply cannot cope with regard to roads, schools, shops and leisure facilities. Or employment - there is very little within the town.

I would like to object in the strongest terms to the NHDC Local Plan proposal and specifically the 3290 new homes indicated for Baldock by 2031 (both the 500 in Clothall Common and 2800 on land North of Baldock).

Baldock does not have the infrastructure or amenities to support such development.

In addition the plans are such that the unique and individual character of our small market town would be utterly destroyed by these proposals.

I do not consider that the plan was positively prepared, justified, effective or consistent with national policy.

Please confirm receipt of my response.

Please find enclosed my response to the NHDC 2016 Local plan.
My objections are mainly based around the proposals for Baldock, in particular the land to the North of Baldock, BA1 - referred to as Blackhorse Farm, but which is in fact known on the Ordnance Survey maps as Bygrave Common.


I believe the Local Plan is Unsound, and Not Justified because of the following:


1. Traffic, noise and pollution during the BA1 houses construction period
Site - BA1; Policy - SP14; Paragraph -

During the extended period to build 2,800 houses to the north of Baldock, this will cause the traffic along North Road to increase, and the current traffic to be disturbed by the additional construction traffic.
It may even affect the Police forces who I understand occasionally use the North Road into Baldock for high-speed pursuit training.
The building of the houses will cause noise, traffic and air pollution problems for local residents.


2. Traffic through and around Baldock - increased volume and noise
Site - BA1; Policy - SP14; Paragraph -

With the building of 2,800 houses to the north of Baldock (BA1) there will be at least one car per household which may choose to gain access to Baldock for shopping, and to local towns for commuting to work.
At the moment all of this traffic will try to pass south under the Baldock railway bridge, causing even more congestion down London Road, into Station Road up to the traffic lights on the corner of White Horse Street.
If as suggested there may be a northern loop road built from London Road to the Royston Road / Bypass roundabout, the traffic for Baldock will turn west along the Royston Road to the Whitehorse traffic lights. The resulting queuing at the traffic lights will add to the traffic congestion and air pollution.


3. Traffic through and around Baldock - increased Air Pollution
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

Good Air Quality is critical to the public health. Concern has already been raised within NHDC about the poor air quality near the Paynes Park and Three Moorhens roundabouts in Hitchin.
With a greatly increased flow of traffic into Baldock passing through (and waiting at) the Whitehorse traffic lights, this will have an adverse effect on the air quality for the local residents, including residents of the retirement homes close to the traffic lights. Poor health in the local residents will result in more visits to the local Baldock Surgery, and to Lister Hospital for serious cases. Poor Air Quality in Baldock was part of the justification for the current Baldock Bypass. Poor Air Quality has not been included in the Local Plan.


4. Baldock Railway Bridge footpaths- inadequate for more pedestrians from the new houses
Site - BA1; Policy - SP14; Paragraph -

The footpaths under the Baldock Railway Bridge are narrow, especially on the east side of London Road, where it is just about wide enough for a mother and push chair. If she has a toddler, then it can be dangerous, especially if none rush hour traffic is speeding under the railway bridge inches away from the pedestrians. Pedestrians from 2,800 houses to the north of Baldock will only exacerbate this problem.
Baldock Railway Bridge is low (4.4m / 12ft 6in) and lorries hit the bridge several times per year. This can cause disruption to London Road traffic for a few hours, and can even affect pedestrians if the bridge strike is serious. I do not believe this problem has been highlighted in the Local plan.


5. Baldock Railway Station - inadequate for more commuters from the new houses
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

There is a probability that many of the new residents in the houses to the north of Baldock (and elsewhere in Baldock) will have bought their houses to be near to the Baldock Railway station, where they can commute to their place of work, be it London, Cambridge, or stations in between. If these commuters choose to drive to the station, they will be delayed by the additional traffic. The current provision for car parking at the rail station is limited, and will not cater for the increase in commuter's cars.
Likewise only the 4 and 8 carriage trains can stop at Baldock Station, due to the short length of the Platforms. The rush hour trains are already full to standing capacity. Either more trains will be needed, or the platforms would need extending (by the Rail operator) to take the new 12 carriage trains.


6. Baldock Town Centre Parking - inadequate for more shoppers from the new houses
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

Since the re-development of Baldock Town Centre parking, the parking spaces are just adequate for the current population of 4,500 houses. With an additional 3,300 houses in Baldock, the car parking spaces in Baldock will be woefully inadequate, and shoppers will drive elsewhere to park and shop.
For the 2,800 houses to the North of Baldock, it will be just as easy to drive up the A1 to the shops in Biggleswade, Bedfordshire. Their alternatives could include driving to Letchworth, Hitchin and Stevenage, where parking is currently just about adequate. Wherever the shopper's cars go, they will cause an increase in local traffic volumes, noise and Air Pollution, giving poor Air Quality for the local residents.


7. Sewage system in Baldock will need enhancing for the new houses
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

At the moment all the sewage from the 4,500 Baldock houses flows to the Ivel Springs Sewage Pumping Station, where it is pumped up to Norton, along a pipe which passes under the Baldock Football ground, and over the Norton Road Bridge, passing over the A1M road. From Norton the Baldock sewage flows by gravity down to the Stand Alone sewage works in Letchworth. During a conversation with an engineer at the Baldock pumping station, he believed the current pumps and pipe are close to capacity, and would have to be doubled in size, to cater for the additional 3,300 houses in Baldock. This required increase to the sewage Infrastructure has not been mentioned in the Local Plan.


8. Surface water run off and flooding in Baldock
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

With 174 hectares of prime agricultural land being covered over by houses, roads and driveways, the rain water will not be able to soak into the land, as at present where it adds to the underground water table.
All of this run-off ground water will either pass into the already overloaded sewer system, or flow into the adjacent River Ivel, where it would disrupt the fragile eco system. I believe this water run-off problem has not been considered in the Local Plan, as has the effect on the River Ivel eco system.


9. Provision of Water to the additional houses in Baldock
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

The local water authority are already trying to move all of Baldock's residents to a metered water supply, due to the lack of water available from the local Aquifer under Weston Hills. A presentation was made by the water authority to the local Baldock councillors saying they were unable to pump water down from the Grantham reservoir, because Aquifer water and reservoir water should not be mixed (due to differing salts and acidity), and that it can cause problems to the water network if it was mixed. The additional 3,300 houses in Baldock (and more houses in other North Herts areas) will only make the water shortage more critical. I believe this water shortage has not been considered in the Local Plan.


10. Lack of spaces for additional pupils in Baldock Schools
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

With an additional 3,300 houses in Baldock, many of these new houses will contain families whose children are of school age, and will need to travel to a school each weekday, probably by car. At the moment the headmasters of local Baldock schools say they do not have the space for these additional pupils, and the schools will need to be increased in size to take the additional pupils. An alternative would be for the pupils to attend schools in other areas, travelling by road, causing further traffic problems.
I believe the needs of children from the additional 3300 houses in Baldock, have not been fully addressed in the Local Plan.


11. Increased pressure on the Baldock Doctors Surgery
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

With an additional 3,300 houses in Baldock, many of these new houses will contain young families. It is probable that the parents would normally be initially quite healthy and would not require a doctor. Where there are children, the parents may need to consult a doctor regarding injections, breakages, child illnesses, etc. The Local Plan does not take this need into account.


12. Loss of Green space in and around Baldock
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

As part of the Green Space Management Strategy, NHDC have identified green spaces in the following North Herts towns for improvement / revision - Hitchin (12), Letchworth (12), Royston (9), Great Ashby (9). Baldock currently has only 5 green spaces for the current local residents. This is inadequate for the health and fitness of the current residents in 4,500 houses. No mention has been made for the provision of additional green spaces for the new residents in the proposed 3,300 new houses in Baldock (which are to be built on Green Belt land). It would be useful if the new houses were separated from the existing houses by green spaces. This lack of green space in Baldock has not been addressed in the NHDC Local Plan.


13. Not all available land around Baldock has been included in the revised Local Plan.
Site - BA1, BA2, BA3, BA4, BA5, BA6, BA7, BA8, BA9, BA11; Policy - SP14; Paragraph -

Additional HCC (Herts County Council) land had been previously identified as being available to the South of Baldock (to the south of the Bypass, near the old airfield, off the A507 Buntingford Road), but this has not been considered by the NHDC planners, and has not been included in the latest NHDC Local Plan.
Likewise, some of the farmers in the Bygrave area have additional land, which could be made available for housing. I believe the owners of this additional land should have been proactively approached re the inclusion of this additional land in the revised North Herts Local Plan.


14. Duty to Co-operate / not Positively Prepared
The North Herts Local Plan is taking into account the needs of Luton.
I believe South Cambridgeshire should likewise take into account the needs of North Herts, by considering the land in the Odsey area around Ashwell Railway Station for additional houses for North Herts.
This area has excellent links to the road (A505 Royston to the A1M), and rail (Cambridge to London Kings Cross) Networks.
The land to the south of the A505 is HCC (Herts County Council) land and could form part of this new development. It is on a slight slope, but houses in many parts of England are on much steeper ground.
A bridge over the A505 would give easy access to the Ashwell Rail Station (which has land available to be extended to take the 12 carriage trains, unlike Baldock Station).

I wish to make the following representations in response to the Submission Draft Local Plan.

The whole plan is "unsound" because it is fundamentally flawed in a number of ways:
* The supposedly objective assessment of housing need is based simply on projections produced by the Office of National Statistics. No attempt has been made to validate these against past trends. In fact they would require that houses are built in North Herts at a greater rate than has ever happened in the past. Since the plan is for the period from 2011 to 2031 a quarter of the plan period has already happened. During that time the rate of development has been less than half that projected for the plan period as a whole.
* The housing target has not been influenced by the need to limit or avoid building on green belt land. The government has said that assessed need does not, on its own, represent a case for building on green belt land, but that is exactly what the plan argues.
* The mechanism that has been used for identifying sites is flawed. The Council simply asked land owners or developers to suggest sites that they would like to develop (at least one major site has been put forward by a developer who does not own the site concerned). There has been no attempt to identify sites that would be suitable for meeting housing need whilst meeting community and sustainability requirements. The result is that housing is proposed in the locations that suit the developers rather than those that provide the best solution for the community.
* The plan includes inadequate provisions to would ensure that brown field sites will be developed first with green field and green belt sites only following later if the demand is shown to exist.
* The traffic impact assessment is totally inadequate. The plan relies on an assessment that covers Stevenage, Hitchin and most of Letchworth and Baldock, together with another that covers Royston. The largest development proposed at Baldock is beyond the edge of the area covered by the traffic model. In addition whilst the effects of Stevenage and Welwyn Hatfield are considered, Central Bedfordshire and the proposed developments there are completely ignored. The supporting report sets an absurdly high threshold for congestion, only regarding junctions as congested if they will have "more than 100" vehicles queuing at the end of the peak hour. The proposed mitigation measures fail to identify the extent to which the problem will be improved and the proposals appear to take no account of traffic diversion to rural or residential roads.
The second level of objection is to the flaws in the proposals for individual sites:
1. GA2 - Tilekiln
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For most of its length if follows a footpath or a poorly defined field boundary. The strange shape of the site relates to land ownership rather than any natural feature and demonstrated that this is not a suitable boundary.
* Access to the site from Great Ashby is restricted to a narrow path through a wood land beneath powerlines.
* The site is proposed as the location for a school, but placing a school right on the edge of a settlement in this way will ensure that many children are brought by car.
* The development will clearly relate to Stevenage (despite being in North Herts) yet is remote from any of the town's facilities and will encourage longer car journeys to shops, secondary schools and leisure facilities.
2. GA1 - Roundwood
* Access to the site is unsatisfactory, requiring measures to prevent parking on roads in Great Ashby that are outside the site.
3. NS1 - North Stevenage
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For much of its length it is in the middle of a field.
* The site will clearly result in coalescence of Graveley with Stevenage. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* In addition it appears that access issues may not have been adequately considered.
4. WE1 - Weston
* Access to the Hitchin Road site needs to be from Hitchin Road and not from The Snipe.
*There is no pavement along a section of Hitchin Road that residents in the new development would need to use to get to the school, the shop and other village facilities. Any development here should require this to be addressed.
5. BA1 - Baldock
* The traffic assessments do not identify what would be required to make the large site north east of Baldock achievable.
* The land is admitted to "make a significant contribution to the Green Belt purposes".
* The site will clearly result in coalescence of Bygrave with Baldock. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* The National Planning Policy Framework requires that, for proposals of this sort, infrastructure should be planned at the same time as the Local Plan is prepared but there are no details of this in the plan.
* If built the proposed road linking the A505 with the A507 north of Baldock would have inevitably see use as a Baldock eastern by pass. Its specification and construction would need to reflect this use which would require placing significant parts of the road in a cutting to avoid unacceptable impacts on both the urban area and the adjacent countryside.

I can totally see why you want to build houses in Baldock, but please hear me out before you make rash decisions that will last forever.
As I said before, I can see why you want to build-More people are wanting to buy affordable and pleasant places to live. However there's starting to be too many people who are wanting to do this in England, where this is becoming rarer and harder to do, and it's the simple fact of there just isn't enough space so we've had to build more and more until we're now pushing it to the limit-building on greenbelt and changing the rules so we can.
My proposition to solve this is to build apartments; Places where we can still call home, have a pleasant place to live, and that is affordable! And, that way we can still offer work to builders, architects and hundreds of more other people! At the same time using so much less space-therefore clogging up the world dramatically less, also letting farmers be able to still produce locally!

Talking about clogging up the space we've been given the responsibility and honour to look after, it's not just people we're affecting, it's also nature; a rare species of bird, called "Corn bunting" is really endangered. Worser yet, it lives where we're planning on building all these thousands of houses. It has a puny amount of alternative places to escape to.
On the other hand, as you've pointed out, more people coming here could benefit the town. And I've thought long and hard about that and the trouble is, Baldock wasn't designed to have thousands of houses added to it, and I'm not sure how it could cope. Take North road for example, it can't be expanded and it would desperately need to be if this idea was carried out, the traffic would be impossible. Or schools, 3000+ of new homes would definitely bring families, with kids who needed to attend a local school, however our local schools won't be able to cope with this number, yet no one is very enthusiastic with the idea of new schools-which I can also understand; It will cost money we don't want to have to spend. If the housing was more evenly distributed we wouldn't have this problem though.
Getting rid of too many farms isn't wise either-If there's another war in England at any time and we have to depend on local farming, there's not going to be any to depend on! I walk my dogs daily in the fields with my family, and I couldn't imagine not having it there-how tragic would it be for someone to grow up and never run till you've reached the top of the hill and are fully out of breath, or climb to the highest hay bale at harvest time, dance in the rain and get muddy from head to foot, go for spontaneous picnics, sledge down hills or just go on a dog walk to clear the cobwebs out in your brain.
I know we have to build more places for people to live in but, Please, please, PLEASE let us try and make the smallest damage we can, and Plleeaaassee , let us leave greenbelt to be, it's purpose was to be enjoyed by the community, not get ruined with concrete, bricks and cars.
Thank you SO much for using your time to read this and Please, take caution and re-think it through-When greenbelt, or any land, is gone, it's gone forever.

The idea that this plan is going to work out and not cause any major problems is ridiculous, I can, definitely, understand why we need to build more houses but please, let us think this through logically and very, very carefully before we make these major decisions that will affect our town permanently.

Before I wrote this I kept thinking, "There must be another way we can solve this" and, although at first this seemed virtually impossible, I'm beginning to see how we can overcome these challengers we've been faced with. Obviously, we have to build more places where people can live, however we have to find the balance between, building more homes so we all can live in a comfortable place we can call home, or, from North to the South of England becoming a never ending mass of concrete, roads, and tar.-We Can't let that happen.
One way to try and lessen the damage is building apartments - Places we can still love as a home, that's an achievable goal for a price affordability, And clogs up our country drastically less.
It's us who have been given the honor of looking after Baldock, and with that title also comes with the responsibility to look after everything in it. Including the nature that lives here, take the "Corn bunting" for example, it's a rare species of bird that lives on our greenbelt we are planning building on-It's terribly endangered and is on the red list. It would have a pathetic chance of surviving if we were to bulldoze it's home. We can't be selfish with this and only think of ourselves benefiting with this endeavor.

Also, in some ways, we would not benefit from this plan-Greenbelt has been preserved for a reason, it's part of the community. It holds water-preventing flooding, catches carbon, Having a countryside everyone can explore and cherish. Furthermore, most of green belt - about two-thirds - is in agricultural use. This cannot be considered of low environmental value when global population growth and climate change are putting increasing pressure on the land we farm, and when we grow less than two-thirds of our own food, now, more than ever, we need to avoid unnecessarily losing our countryside.
Instead, We should, look for more brown fields or derelict buildings to tackle the housing crisis in Britain-more than seven million pounds of taxpayers money has been spent securing and maintaining empty buildings in Hertfordshire alone, that's a lot of money, and space, we could have saved.

Thank you SO, so much for using your time to read this, We have to build houses, that's a fact. But PLEASE, let us tread carefully, and not steal greenbelt away from future generations.

I object to North Herts District Council's Local Plan 2011 - 2031 as follows.
I object to NS1, GA1and GA2 proposed housing for Stevenage expansion into Hertfordshire Green Belt; EL1,EL2 and EL3 proposed housing for Luton overspill in to Hertfordshire Green Belt; BA1 proposed near doubling of the town of Baldock into Green Belt land; HT1 proposed incursion into Green Belt bringing Hitchin within a stone's throw of Letchworth. It is against Government policy to build on Green belt land unless "very special circumstances" pertain (see Appendix 1). Nowhere in the Local Plan are any "very special circumstance" identified. The Green Belt was expressly put into place to curb urban sprawl. The siting of these proposed developments, mostly adjoining already existing estates is typical of the urban sprawl long discredited by town planners for its poor environmental impact and weakening of community. Several hitherto distinct village communities such as Cockernhoe, Gravely and Bygrave will be either absorbed. The Green belt promotes physical and mental health by providing recreational space. It is vital for biodiversity, especially when 60% of British wild species are in decline. Up to the present, NHDC has a good record of management of the Green belt. In its Biodiversity Action Plan of 2005 it pledged to protect it (see Appendix 2). This measure, having had no formal modifications since, is deemed to be still in force. Therefore I question the legality of NHDC's proposed flagrant disregard of it.
The site LG1 is ancient cultivated land dating back to medieval times and probably far beyond. Its ditches, banks and hedges are artefacts of early agricultural systems of archaeological significance. There are a number of pollarded oak trees estimated to be over four centuries old. These features carry their own biodiversity which has evolved over the same time-span. The richness of biodiversity is also the result of soil diversity, generated by the particular mix of sand, gravel, chalk and boulder clay laid 500,000 years ago in the last glaciations and known to geologists as 'The Letchworth Gravels'. NHDC has played its part too, cutting down the use of agri-chemicals and encouraging wide field margins. 114 bird species have been recorded, 28 of which are endangered, together with Great Crested Newt, Brown Hare, Common Toad, Polecat and 3 rare butterfly species (see Appendix 3). There is a House Sparrow roost of over 300 birds, the biggest in the county which is now under consideration for a designation of protected status. There is in increasing currency an idea that land lost to the Green Belt can be balanced by new Green belt designation elsewhere. Quite apart from the fact that there is no spare land in North Herts for such new designation, an eco-system such as that of LG1 cannot be moved as its centuries of evolution has been specific to that site.

I object to site LG1 because of the threat it poses to the unique heritage of Letchworth. This heritage is that of the world's first garden city, embodying influential principles of town planning and social welfare. Proximity to the open countryside was one of them, to which end the founding father, Ebenezer Howard, proposed to limit the population to 32,000 (thereby limiting the footprint of the town) (see Appendix 4). He further stated nowhere on the urban boundary should be more than 15 minutes walk from the town centre. Such principles have already been infringed but this is no reason to abandon the spirit of them; there is still a heritage to be preserved if tourists and visiting students of town-planning from all over the world are not to be disappointed. Another principle was the town should be self-sustaining, in the sense that the population would work locally, so housing and industry were carefully balanced. Rather than use the opportunity to restore this balance, the Local Plan proposes to upset it further. With the increase in population generated by LG1, plus the change of use from industrial to residential of many of the smaller sites in the town under the Plan, the percentage of residents employed locally will sharply decrease. Letchworth will become predominantly a dormitory town with all the weakening of community that entails. The increase in commuter numbers will cause insuperable problems for road infrastructure as Letchworth's narrow roads were designed for low car use. In a self-sustaining town everybody could walk to work or school. The crucial routes from LG1 into the town centre and station are already bottlenecks: narrow roads lined with grass verges and specimen trees, some rare, which cannot be removed for road widening without completely destroying the distinctive garden city ambience.

I object to site LG1 because of the circumstances of its proposed sale by the owners. The owners, Letchworth Garden City Heritage Foundation, propose to abdicate its responsibilities to protect and preserve the site. The Foundation was set up by Parliament in 1993 to continue the town's development by Ebenezer Howard's the principles, of which the Green Belt was one - the world's first Green Belt. The sale of this land is a betrayal of principle by those whom Parliament has charged to be its protector. The sale of the land could be (and should be) open to legal challenge.

I wish to object to the development site LG6. This land was compulsorily purchased by Letchworth Urban District Council as part of the Jackman Estate land. The Inspector at the time stipulated that it should be left as a Garden City-style green space. NHDC now wants to forget this decision, together with its own Biodiversity Action Plan (2005) which identified the same piece of land as an Urban Wildlife Site to be protected.
I wish to oppose the LG10 which would nearly double the number of households using Croft Lane, part of Norton old village. The pond at Norton is a breeding area for toads and other species which make their way to the pond inevitably crossing local roads especially Croft Lane. Doubling of the traffic would risk wiping them out.

Appendix 1

Extract from Hansard 15.7.2016
Green-belt Land
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18 July 2016
Volume 613
* Philip Davies (Shipley) (Con)
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16. What his Department's policy is on the building of houses on green-belt land. [905899]
* The Minister for Housing and Planning (Gavin Barwell)

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The Government are committed to the strong protection and enhancement of green-belt land. Within the green belt, most new building is inappropriate and should be refused planning permission except in very special circumstances.
* Philip Davies


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I welcome the Minister to his post, although I am sure he is disappointed to no longer be my Whip.
My constituents in Burley-in-Wharfedale, and other villages such as Baildon and Eldwick, to name but a few, are facing planning proposals for green-belt land, with 500 houses proposed for Burley-in-Wharfedale alone. Surely the whole point of the green belt is that it should not be subject to housing, and particularly not until all brownfield sites in the district have been built on. My constituents do not trust Bradford council to look after their interests, so they look to the Government to protect them. What can my hon. Friend do to protect their interests and stop that building on the green belt?
* Gavin Barwell

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I thank my hon. Friend for his kind words and wish his new Whip the best of luck.
If he looks through the national planning policy framework, he will see a clear description of what development is appropriate on the green belt, and a strong presumption that inappropriate development is harmful and should not be approved except in very special circumstances.
* Mr Speaker

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The Whip will certainly need to be a natural optimist.

Appendix 2

North Hertfordshire District Council Biodiversity Action Plan (2005)
Foreword
Diverse rural and urban landscapes, their integral habitats and wildlife, still make North Hertfordshire a very special place in which to live and work. However we should not become complacent, for all is not well. Many changes, some quite dramatic and others very subtle, continue to degrade local habitats, reduce the diversity of wildlife and threaten the qualities of our surroundings.
The importance that your Council places upon the environment that we share, not least with many important facets of wildlife that indicate its health, is clearly outlined within its corporate vision. Its priorities promote conservation of our historic towns and rural settlements together with protection of the countryside.
In the wake of national and international concerns about environmental degradations together with loss of biodiversity, including the tenet to 'think globally, act locally', the Council initiated measures to effect positive local conservation to both habitats and species. Detailed studies and correlation of holdings of data have facilitated a timely overview that elucidates the ranges and status of the District's wildlife and wild places, and have facilitated production of this, our very own Local Biodiversity Action Plan.
With policies and evolving programmes towards effective conservation of the environment we share, the North Hertfordshire Bio-diversity Action Plan meets criteria of the Council's vision and priorities. However, these can only be really workable if each and everyone of us share in the many challenges and commitments required to ensure appropriate care for our surroundings, whether it be in town or countryside
Your Council will lead these challenges but there will be opportunity for all of us to be involved, not least toward education at all levels, joining partnerships and actively supporting the care that our urban and rural countryside needs and deserves.
Local Actions make Global Changes
Leader North Hertfordshire District Council
Councillor F.J. Smith

Appendix 3
BIODIVERSITY OF SITE LG1
Red-listed species
(Red -listed species have the highest conservation priority. In addition, where indicated SAP, some are subject to national Species Action Plans )

Skylark (SAP)
Lesser Redpoll
Common Linnet (SAP)
Cuckoo
Corn Bunting (SAP)
Yellowhammer (SAP)
Reed Bunting (SAP)
Yellow wagtail
House Sparrow
Grey Partridge (SAP)
Dunnock
Common Bullfinch (SAP)
European Turtle Dove (SAP)
Common Starling
Song Thrush (SAP)
Northern Lapwing (SAP)
Woodcock
Grasshopper Warbler
Fieldfare Redwing
Mistle Thrush
Nightingale
Whinchat
Grey Wagtail
Bittern
Red Kite

A further 20 or so species found on the site are amber-listed: unfavourable status in Europe

Other red-listed fauna found on Local Plan site LG1
Brown Hare (SAP)
West European Hedgehog
Polecat
Common Toad
Great Crested Newt (SAP)
Small Heath butterfly
Small Blue butterfly
Wall butterfly

INFORMATION: Brian Sawford: NHDC Countryside Officer (Retd), Curator of Natural History for North Herts Museums Service (Retd).
:Trevor James: Curator of Natural History for North Herts Museums Service (Retd), Director of Herts Biological Records Centre (Retd).
Appendix 4

GARDEN CITIES OF TO-MORROW
Ebenezer Howard
Garden Cities of To-Morrow (London, 1902. Reprinted, edited with a Preface by F. J. Osborn and an Introductory Essay by Lewis Mumford. (London: Faber and Faber, [1946]):50-57, 138- 147.

Let me here introduce a very rough diagram, representing, as I conceive, the true principle on which all towns should grow, Garden City has, we will suppose, grown until it has reached a population of 32,000. How shall it grow? How shall it provide for the needs of others who will be attracted by its numerous advantages? Shall it build on the zone of agricultural land which is around it, and thus for ever destroy its right to be called a 'Garden City'? Surely not. This disastrous result would indeed take place if the land around the town were, as is the land around our present cities, owned by private individuals anxious to make a profit out of it. For then, as the town filled up, the agricultural land would become 'ripe' for building purposes, and the beauty and healthfulness of the town would be quickly destroyed. But the land around Garden City is, fortunately, not in the hands of private individuals: it is in the hands of the people: and is to be administered, not in the supposed interests of the few, but in the real interests of the whole community.

I am writing to express my concern at the lack of sporting facilities currently available for the population of Baldock and my fear of what will happen if the proposed development of 3500 new homes should go ahead.

Baldock Town FC needs somewhere they can call home, currently they use a whole mush mash of pitches which is neither practical for families, cost effective for the club or conducive to the building of what could be an amazing community hub.

In addition the swimming facilities at north Herts leisure centre are woefully inadequate for the existing population, let alone all for the proposed increase.

I hope you will consider both these points as part of the plan for any expansion around Baldock.

I understand the need to build lots of new houses in this country but like many local residents have serious concerns and misgivings about the proposed plan for 2800 homes on land North of Baldock.

Baldock is currently a thriving ancient market town, recently revived following the opening of the bypass. If there is a huge influx of people living nearby that
wish to use all the facilities on offer then I fear we will become swamped. Where will the extra cars park ? Is there to be a large car park developed somewhere
in the town? If parking becomes a problem again as it was before then people, both new and existing will be put off coming into town and the newly found
prosperity will be destroyed.

I am now a grandmother but it doesn't stop me being concerned for the future of the local children. Our schools are already full and the new development will
as has been acknowledged need both primary and secondary places. Will these be provided Before houses are built and families move in ? I suspect not and I fear
even worse that they will never be provided.
I have heard of developments where developers have promised certain amenities but have then renaged on their promise and have suffered a 'fine' instead. An amount significantly
lower than it would have cost to fulfil the promises. What safeguards are there to stop this happening.?

The practicality of access is also a major concern. We already have congestion onto the A507 from the Ashwell road which would be badly affected if more traffic was
allowed access onto this small country lane.
The rail bridge and crossroads in Baldock cannot be enlarged due to the number of beautiful and historic buildings surrounding it. How can we expect several thousand more cars to pass through this way without causing mayhem ?
If a bridge it built over the rail line to gain access to the A505 who will pay ? It will be very costly and only if the Rail authority allow it.

I have heard the expression 'the green belt can be moved' on several occasions, but the loss of natural habitat will destroy wildlife habitat and who will tell them that their homes are being moved !?

I feel it very unfair that there are so many houses being proposed so near to Baldock. It will almost double it's size. Why can't there be a more fair and even distribution of the development that is needed.

I'm writing to oppose the Baldock development. I had used the consultation software but the design of it was impenetrable and heavy with planning jargon, it refused to register my application and then lost my details. therefore I'm writing with my objection.

It's grossly unfair that Baldock should be expected to take an extra 2000+ houses while surrounding areas with larger populations are absolved from pulling their weight.

The 2014 consultation on traffic flow under the railway bridge bears no relationship to the level of congestion experienced at the present time. Almost any time I leave my house, there's a huge queue. Jamming two thousand houses' worth of extra traffic will lead to gridlock and unsafe levels of traffic.

No clear solution has been proposed to get around the choke point of the railway bridge. The pavement is far too narrow. My 83 year old mother has almost toppled into traffic on more than one occasion. She would find it impossible to cross the road with any more traffic.

Frankly, a local MP was astounded that this scheme was going ahead with the railway bridge the way it was. He said they would have to abandon this scheme because of it. Not only has this not been abandoned, it has gone ahead with no plans to solve problems of congestion in the station, surrounding roads (including mine) and traffic flow. The railway company has decided they want to reduce the train service to Baldock. They knew nothing of these plans. Ours is a commuter town, facing reduced train service and irresponsible rises in population without regard for how this will work in practice. I therefore oppose this scheme. We opposed this before and were ignored. I hope that someone will listen to us now.

I am writing to object to the North Hertfordshire District Council's Local Plan 2011-2031, and in particular to proposed site BA1, the Blackhorse Farm site to the north of Baldock. as I believe it does not fully meet the soundness criteria laid out by the National Planning Policy Framework (NPPF).

1.Traffic congestion:
*The junction where the A507 and A505 cross already suffers from considerable congestion during peak periods, and it has been getting steadily worse in recent years. These cross roads are constricted by listed buildings, one of which has been damaged several times as a result of limited space to manoeuvre for some of the larger vehicles that use these routes. The 14'6" railway bridge on Station Road is frequently hit by lorries, despite recent work undertaken to reduce such incidents. These traffic issues are further exacerbated by any incidents occurring on the A1. Building 2800 houses (equating to c. 5600 cars) is only going to cause gridlock at an already excessively congested junction.
* Policy SP14 in the local plan suggests a new link road between the A505 and the A507 so that not all traffic from the proposed site will have to use the crossroads, however inevitably not all of the additional vehicles will elect to use the new route, therefore substantially increasing congestion at the crossroads.
*The NPPF (section 4) indicates that as part of promoting sustainable transport, a transport statement/assessment should be generated for any developments that generate significant amounts of movement. To my knowledge, there is no evidence that such an assessment has been generated which means the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

2.Green Belt:
*It is not acceptable to remove green belt status from land surrounding Baldock simply to meet housing requirements, even if land elsewhere is awarded green belt status to compensate. In my opinion this calls into question the whole concept of green belt policy.
*The proposal for the Blackhorse Farm site is a clear demonstration of urban sprawl, precisely the kind of development that green belt status is intended to prevent. This area is good quality agricultural land, and a haven for walkers, runners and cyclists.
*The NPPF (section 9) states that once established, Green Belt boundaries should only be altered in exceptional circumstances. NHDC have failed to demonstrate what these exceptional circumstances might be and therefore the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

3.Air quality and pollution:
*Baldock is located in a valley and as a result suffers from high levels of air pollution. The bypass to the east of Baldock helped to allieviate this initially, but traffic volumes (and therefore air pollution) have subsequently risen in recent years resulting in pollution levels in Hitchin St and Whitehorse St now being in danger of breaching levels permitted by EU law.
*The additional vehicles resulting from the proposed development on the Blackhorse Farm site will increase traffic in and around Baldock, thereby increasing pollution levels further and adversely impacting the health of local residents.
*The NPPF (section 1) indicates that to prevent unacceptable risks from pollution, there is a requirement to ensure that any new development is appropriate for its location, and the effects of pollution on health, and the potential sensitivity of the area to adverse effects from pollution should be taken into account. Given the already excessive levels of pollution currently plaguing Baldock I would suggest that this has not been taken into account and that therefore the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

4.Employment:
*A significant number of Baldock residents commute outside of the immediate area for work, to London, Cambridge, Stevenage, Welwyn/Hatfield and further afield, particularly higher skilled residents who are less able to find appropriate employment in the immediate vicinity.
*Policy SP3 describes additional employment provision for the area, and also indicates that the council will promote and support the expansion of the knowledge based economy in the area. However such action is unlikely to absorb the majority of the working population likely to inhabit the dwellings proposed for the Blackhorse Farm site. Realistically these people will be commuting in the same way as existing residents of Baldock, and placing increased pressure on already congested road and rail networks.
*The NPPF (paragraph 34) states indicates that plans and decisions should ensure developments that generate significant movements are located where the need to travel will be minimised. Since sufficient employment opportunities are unlikely to be made available in the immediate area, and therefore result in a significant increase in the number of people commuting outside the area, I would suggest that the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

To conclude, I feel that the proposal for the development of the Blackhorse Farm site is hugely inequitable when you consider the suggested number of houses in comparison to the existing number, and then further compare this to the number of houses that other towns in the local area have been asked to accommodate. It will dramatically compound already existing problems with regards to traffic congestion, pollution, and access to local amenities, and furthermore has the potential to destroy a charming town centre. I support careful, well thought out development that will enhance the local area, but what is being proposed is far removed from this and cannot be a good thing.

I would like to comment on the North Hertfordshire District Council's Local Plan 2011 - 2031 (Proposed Submission, October 2016). Particularly, I wish to object to the massive proposed development at the Blackhorse Farm site to the north of Baldock.

The proposed siting of the development, BA1, is ill-considered not only in terms of its shear size but also the majority of the land is on a greenfield site used by many villagers and tourists for recreation, cycling, horse riding and dog walking. Next is plans or rather a lack of for schooling where this was hardly mentioned in any of the documents especially how existing schools in and around Baldock could absorb a potential massive influx of children needing education. Shoehorning would jeopardise both the quality of teaching and learning at these schools which would result in negatively impacting the Ofsted reports and in turn steers away anyone moving to the area.

Such overdeveloping would impact everything in and around Baldock: resources, roads, access, parking, noise and air pollution etc which surely makes no sense to put it all into one historic town. The more pragmatic consideration perhaps should be shared with other neighbouring towns and cities where the overall impact are moderated.

Our family moved to the small hamlet of Bygrave as it is rural and offers a quiet and peaceful lifestyle. This proposal would mean that our quiet hamlet would become engulfed by a larger town. Is this even legal?

I strongly object to the proposed plans which will severely affect not only our villages in the surrounding area, but also the way of life for everyone living in and around Baldock.

I grew up in a village in the Midlands, this is now a suburb of Birmingham. Our family moved to a market town several miles south of Birmingham. This is now an overspill area for Birmingham. The heart was removed from the town it is surrounded by duel carriageways and housing estates and is unrecognisable from the quaint town it used to be. The roads are always congested, the fields have all gone in the name of progress.

I fear that the number of extra houses proposed for Baldock will swamp the area with not only houses, but with a huge number of people who will have requirements such as shopping, schooling, doctors, dentists, etc beyond the capability of Baldock. The number of cars trying to negotiate the streets at the moment already cause congestion for most of the day. By building extra roads, this won't improve the traffic flow through the town, there will just be more cars fighting for the same space. The railway station is already pretty busy at rush hour with commuters, the trains already full, and there is insufficient parking. What will happen if the town grows to the proposed proportions? Where will all the people work, travel, go to school etc?

I really can't see how building such a huge number of houses will benefit either the town, the area, or the people, new or old.

I would like to add to the comments already made on this subject.
I approve of the use of land between Clothall Common and the new bypass as I think this is good use of that land.
However I think that the proposal north of Baldock is too much for a small town like ours. Any proposal which nearly doubles the size of the population is unfair on the current residents who will have to put up with the chaos before (as in now), during and for many years after the process has completed. I am sure that existing Baldock residents lives will be poorer if it goes ahead.
Everywhere should have to take it's share of population growth but this is a step too far.

We would like to object to the proposed housing development to the north of Baldock (SP14).
It belies an incorrect housing strategy and would simply provide a commuter estate for people working in London, etc., even though the railway company is planning to slash services. West of Stevenage is surely the better option.

Baldock cannot handle this massive increase and should be allowed to develop naturally.

I strongly object to the Proposed Submission Local Plan 2011-2031.
The quantity of houses proposed is way to many, Baldock has taken 1000 years to get to it's current size to double it in 20 years puts a strain on the town that diminishes life in this old market town.
There is not the work here for that number of new people proposed. You are building houses for commuters with no additional infrastructure for travel. Better build houses where there are jobs.
The current traffic congestion in Baldock is currently significant, particularly at the White Horse Junction, additional vehicles from the proposed houses to the North of Baldock are not given sufficient consideration in the plan and will create serious problems.
I am greatly distressed at this carbuncle of a plan which no one locally wants.
I am further distressed that I feel I am wasting my time writing this email as I suspect the objections will be over ridden by outside influences ie people who do not live in the town, that is not right, fair or democratic.

I would like to express my sincere reservations about plans to expand Baldock further than the Clothall boundary onto land which is currently farmland and green belt.

It is my understanding that Herts CC currently own the land and so its re-development is, of course sadly inevitable. I would like to point out, however that I suffer the daily problem of trying to exit Walnut Avenue onto South Road in order to get to work. The traffic on South Road is so heavy that a significant delay is inevitable because of cars from this estate queuing for their chance to join the existing heavy traffic from both directions. It is often the case that residents from the South Road cottages opposite Walnut Avenue park their cars on the junction thereby preventing two lanes from exiting, which means that the wait is even longer. If the car in front wishes to turn right in the direction of the A507, the wait is interminable. I shudder to think how much worse this will be with all the extra cars from the new houses which are planned using the Laxton Gardens/ Walnut Avenue route to access the main road.

I do not think that our current road system can accommodate all this extra traffic. Baldock is already very congested, please reconsider the plans as they currently stand, life will be really miserable if they go through.

I wish to object to the NHDC Local Plan, with particular reference to the Blackhorse Farm development to the north of Baldock as it fails to meet the following "Tests of Soundness":

"Effective - the plan should be deliverable over its period 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 on the National Planning Policy Framework"

"Justified - the most appropriate strategy when considered against reasonable alternatives."

Local Traffic Congestion and Pollution in Baldock

There is a traffic bottleneck in the centre of Baldock, at the crossroads/traffic lights where the A507 (North Road) meets the Royston Road (was the A505 until the bypass was built). This junction has a large number of major traffic routes that converge at this single point (A507 traffic in both directions, traffic from A1 north heading to A507 and A505, A505 traffic heading to A1 North or A507, traffic from outer-lying villages joining any of the routes just mentioned). This junction is always congested, with major queues during rush hour, particularly heading along North Road, further than the last houses on the very outskirts of Baldock, heading out towards the A1 services. In fact even outside rush hour there are often queues that extend to the edge of town.

It would be very difficult to alter this junction as it surrounded by very old listed buildings. One of which in particular has suffered several hits, and significant damage over the last few years from lorries or vans misjudging the tight corners.

Pollution in this area is particularly bad. Baldock is in a natural bowl and in the past has always suffered with air quality problems, causing occurrence of asthma in children to be much higher than the national average. These issues were partly dealt with by the development of the Baldock bypass which took traffic from the A1 at J9 wanting to join the A505. Since then however, I believe that air quality is once again approaching very dangerous levels (apparently close to breaching EU standards), and as I regularly have to walk down past the station with my 3 year old to get into town, I feel extremely worried for his health!

In addition, I am extremely concerned about the proposed link road between the A507 and A505. It suggests that residents of the new development will have direct access onto North Road. A development of 2800 houses brings with it as standard, 2 cars per household - an additional 5,600 cars. This would hugely aggravate the current pollution issues, and essentially create gridlock at an already ridiculously congested junction. Also, I have seen an options paper created for the council which suggests that a number of houses could be developed on the Black horse farm site without any need to build the link road (therefore a cheaper option), instead access would be along Bygrave road. This is of immense concern to me, as Bygrave Road is a small lane leading to a small residential street - it is absolutely not designed to take traffic from a development of several hundred houses.

Finally, the Station is situated in this congested area (on North Road, near the crossroads). Congestion will only get worse with such huge influx of people. It is already dangerous trying to get in out of station due to poor visibility as a result of the queuing traffic, and dealing with drivers already frustrated by the lengthy queues. This situation can only be exacerbated by the number of new commuters that 2,800 houses would bring.

The National Planning Policy Framework requires that a transport assessment is undertaken for large scale developments. It states that "development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe". However I have seen no evidence that any transport assessment has been undertaken, or any suggestions as to how these issues can be mitigated, therefore the plan clearly falls foul of National Planning Policy. The impacts of the suggested development will be extremely severe, both in terms of extreme congestion and high levels of pollution around the bottleneck at the A507 / Whitehorse Street, and should therefore be rejected in favour of more careful and sensible planning.

Wider Traffic Issues

The local plan intends to increase Baldock's population by 80%. Baldock has limited employment opportunities, therefore workers would have to commute outside the town which would add to the commuter traffic on an already congested road and train network. I can only assume that a large majority of commuters will be heading South, where transport links are already at breaking point. I travel to Hatfield for work and over the last 2 years have been shocked by the significant increase in traffic volumes and travel time during morning and evening rush hour, every day of the week. Why is it necessary to add further pressure when queues and delays are already at completely unacceptable levels? We need a solution for the existing traffic problems, not for them to be exacerbated by such significant population expansion. How are the new and existing residents going to get anywhere? I feel that in this respect the plan is not effective.

The Unacceptable Apportionment of Housing to Baldock and Impact on the Town

Baldock is classed as being of national importance for its historic character (only one of 5 towns in Hertfordshire), with a pretty centre consisting of beautiful character buildings. It has been singled out for a hugely disproportionate allocation of new houses both in terms of the size of the town itself but also in relation to the other towns in North Hertfordshire. Should the proposed developments come to fruition, they would increase Baldock's population by 80%, which will have a hugely magnified impact on our historic market town. Development should be appropriate to the existing size and character of the town, not a sprawling concrete development that is out of keeping with the existing community and outside of current settlement boundaries. The National Planning Policy Framework talks of "developing on accessible sites that are well connected to the town centre". The plan is to create a "bolt-on" settlement, the size of Baldock, right next to Baldock, with an approach into town that is a traffic bottleneck. If it isn't going to become part of the existing town, why build it so close that it destroys the existing town?
The answer? The idea of a new Garden City has been put forward by Oliver Heald MP as a longer term solution. Build a separate town that can support itself with its own centre, it's own employment opportunities, it's own transport network, it's own green spaces and it's own identity, that would be more in keeping with North Hertfordshire. In the meantime, use existing brownfield sites to ease short term pressure, giving breathing space to create something more sustainable in the long term.
Destruction of Greenbelt Land

The Local Plan is clearly inconsistent with National Policy in this regard! Whilst I understand that towns need to change and develop over time, surely ALL possible Brownfield sites must be considered first (including those in Luton, if we are being forced to take on some of their building requirements for no apparent benefit to us). I understand that there are a number of brownfield sites that haven't even made it into the plan. Why is this? Why is an area of prime agricultural land, which is a haven for runners, walkers and cyclists, and also a habitat for endangered farmland birds, being put forward in the local plan first? According to the National Planning Policy Framework, the purpose of greenbelt is to restrict urban sprawl, safeguard the countryside, and preserve the setting and character of historic towns. The Blackhorse Farm development goes against all of these concepts and therefore again falls foul of National Policy. Policy has also made clear that redrawing of green belt boundaries should only take place in defined exceptional circumstances (ie not just for the sake of a Local Plan, or because the council wish to release the land). It is implied that housing need is an exceptional circumstance, however I see nothing exceptional about that - it is an issue across the South East, and therefore not exceptional at all! The plan is unjustified. In addition, National Policy clearly identifies brownfield sites as a potential source of housing supply but in this plan only 20% of houses will be developed on previously developed land, again inconsistent with National Policy.

Finally, I feel that Baldock has had its fair share of development over recent years and I cannot see any positive points that such proposed levels of development would have on our picturesque historic market town, in fact all I can imagine is traffic chaos, pollution and spoilt countryside. I struggle to find any evidence to suggest that there is a need for a development of this scale to meet the needs of Baldock and its local community. I would agree with our local MPs that a more suitable solution would be a 2-stage plan allowing any large scale development to be given the consideration it requires to be a success. Please consider my views and preserve the charm and character of Baldock by not allowing it to expand at such a unreasonable rate.

I am sending an email as I have two young children who are interested in football and other sports and we don't have enough facilities in Baldock. At the moment we don't have a home ground when they play football and more around from one pitch to the next. This is only going to get worse as our population is set to increase.

In view of the likelihood of an expanded population in Baldock, and the currently inadequate resource of sporting facilities for young and old within the town for its current population, the opportunity to address this shortfall within the new development must be considered.

It is of paramount importance to the health and well being of the town that considerable leisure facilities be factored into any proposed development. There must be due consideration for the needs of a community as opposed to merely housing. Sports and leisure should be a key part of the community, both through its local sporting clubs and as an available resource for all.

I trust you will give this matter your most prompt consideration.

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.
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%. At the junction with the A507 and my own road the traffic is horrendous in early morning and evening, between 4.30 and 7.30, we have cross hatchings at the bottom to allow people to access Icknield Way East but this is on the whole ignored, we currently have 4 roads converging here and it already over used.
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:
2. Traffic entering Baldock from the north west on the A507
3. Traffic entering Baldock from the north on the A1
4. Traffic entering Baldock from the north from Bygrave, Ashwell, Steeple Morden, Guilden Morden and all the surrounding villages;
5. Traffic entering Baldock from the north east on the A505;
6. 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
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.

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.
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 year4 . 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 seats5 . 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"

Baldock Planning Meeting, Knights Templar School, 9th November 2016. http://www.dearcustomerrelations.com/save-baldock-trains/ 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. 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.

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

All in all I really don't think the this has been thought about fully and the proposal is very unfair that such a large proportion be assigned to the Baldock area.