Policy SP14: Site BA1 - North of Baldock

I am writing to express my objections to your plans to overdevelop Baldock - in particular BA1 Blackhorse Farm.

I have lived in Baldock for 20 years and it is a historic and quite unique community-based old country town.

The proposals to build 3500 new homes, and potentially doubling its size, are ludicrous. Not only will this destroy our historic country town with overdevelopment but, due to the natural increase in population over the years, our town is already struggling to cope. Building these extra homes is a death sentence to the current residents and will totally transform the visible landscape and our community.

Section 5 (T) Traffic jams into the town are already an everyday occurrence - going into town by car is a 10 minute journey for under a kilometre. The unpopular routing of the Baldock Bypass did little to ease any congestion years ago and I can honestly say that congestion is now just as bad, if not worse, than it has ever been. People travelling to work from the train station already park everywhere - the roads are full and it is a dangerous place for our children to be walking. I urge any of the people in charge of this decision to come to Baldock and sit at the Whitehorse Traffic lights themselves - I spend a lot of my time there waiting in endless queues of traffic.

Walking into town is tricky with the narrow paving under the railway bridge and the amount of lorries and cars. Adding 7000 extra vehicles to Baldock's roads WILL BE SUICIDE.

Section 4 (CGB) This is GREEN BELT LAND - does that not mean anything anymore? Is this even legal? Sections 79 & 80 of The Government's Planning Practice Guidance state that The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence and to preserve the setting and special character of historic towns. Our neighbours who have been farming here all their lives will be out of business - their land filled with houses - North Herts is an area of beauty and the landscape will be irreversibly changed. We should be using existing Brownfield sites - there are lots in the Hitchin, Letchworth, Baldock, Stevenage area.

It is not fair to expect Baldock to take this overdevelopment - it is already growing at twice the rate of Letchworth and Hitchin. It is not fair for it to take 35% of new housing when it is 30% smaller. Doubling the size of the population will damage the well established community here.

The people who live in Baldock will not be the ones who gain from this proposal - our MP Sir Oliver Heald agrees.

Then what about our Schools and Doctors? It's hard to get an appointment already - schools are oversubscribed - people are trying to move into Baldock just to have a chance of their children attending schools here. Will Knights Templar have to continue expanding and building extra classrooms on the old playing field and in the playground - the school is big enough already - if it grows even more it wont be able to keep up the high standards and the level of commitment it has to its students.

And the sewage system, how will that cope? Renewing the infrastructure will be disruptive to residents and businesses - how will this work? Where will all the rainwater go when we cover the fields with concrete - people in Baldock are paving over their gardens for parking spaces every day to get their cars off the road - are we to expect flooding and a change to the ecosystem as well.

I cannot imagine a worse thing to happen here - it is so damaging to expect a relatively small historic town to cope with this, even if there are new schools and roads built - it will be chaos for years and years and Baldock will never recover. Goodbye old Baldock - if this happens you wont survive.

Please, please consider what you are proposing to do to Baldock and Bygrave.

Bygrave means' farm in the fields', it will hardly be that anymore, we can still see the stars at night too because we have no light pollution.

It can take days to see a local doctor, Lister hospital is at capacity, schooling is an issue too.

What about the local farmers in the smallholdings.

How can our small facilities cope with this massive influx of housing.

Baldock is a rural town and Bygrave is in the country, please keep it this way.

Yes, we do need more housing but there are other areas that would not be impacted so much.

Please consider this email as my representation as part of the public consultation on the new housing development within Baldock. I shall be commenting on sites BA1, BA2, BA3 and BA4.

Section 4 - Communities

Site BA1:
Objection to the proposal on the following grounds -
* It is inequitable that Baldock town is to be increased by 80% where as other Hertfordshire towns are expanding by only 10 - 20% and yet Baldock is one of the smaller towns thus less able to cope with the size of development being suggested.
* 2400 new houses in Baldock will cause significant additional pressure on the roads. The cross roads by the station, linking the A507 and A505, is already jammed with traffic during peak periods with long (slow) tailbacks. There is also a lot of industry traffic that moves from the Letchworth industrial estate across to the A505 via Baldock.
* The crossroads cannot be widened as it is surrounded by listed buildings. The proposed road linking the A1 Baldock Services directly with the A505 does not account for the increased traffic which will be moving to and from Baldock rail station.
* Limited parking is available at Baldock railway station.
* Currently, there is one doctors surgery servicing Baldock and surrounding villages (Ashwell, Weston, and Sandon). It is difficult to secure a same day appointment if you ring 10-15 minutes after the opening time. Advance appointments usually entail a two week wait.
* The current primary school provision in Baldock consists of two faith schools (St Mary's and St John's) and 1 non-religious school (Hartsfield). Hartsfield has been oversubscribed for the last 4 years and has a catchment of only c.900m. Many in Baldock have to travel to village schools (Sandon, Ashwell, and Weston) incurring traffic and timing issues for working parents. The new build will generate additional children to be catered for, with nowhere to go and yet it is already significant problem.
* Air quality will be significantly reduced within the town following increased traffic of at least 5000 cars on the roads.
* There is no mention of tree planting to improve the air quality issue, or % of green space planned to aid surface water drainage and improve aesthetics and well-being.
* Construction traffic would need to go through the town causing air quality, noise and congestion issues.
* BA1 housing site is on a slope. Baldock town has issues with flooding when there is heavy rain. Building will reduce the natural drainage resulting in increased risk of flood water and damage to the town centre. Many buildings within the centre are historic and/or listed buildings.
* Its my understanding that the proposed site for building is the habitat for a number of endangered species (birds and bats) which I believe should be protected through either a reduction in the size of the development to limit damage to the species or reduce the density of the housing to ensure species can co-exist with the development.
* Without sufficient new parks and green space, people in the new sites would need to drive to the existing facilities causing congestion and air quality issues.

Suggested changes to the plan:
*Additional railway parking
*Additional town centre parking
*Fewer houses to be built within this site as Baldock road network and current community services will struggle to cope.
*Reduce number of houses and / or density of houses to reduce flooding risk to the town.
*More equitable approach to the build allocation across Hertfordshire
*Construction of Schools and Healthcare facilities to be prioritised within the first phase of development.
*A variety of housing styles and increase the allowance of self-builds; this will reduce the monotony often associated with a housing development.
*Require this site to have a few a children's play parks.
*A large green space with ample parking
*Require a minimum of green space across the site to ensure improved air quality, surface water drainage, and general asthetic wellbeing. Suggest developers imitate the % green space achieved in Milton Keynes, a highly successful build with regards to green spaces. 22% figure 1.7, pg 22 in the MK planning manual, MKDC 1992.
*Tree planting along every public road
*Every house to have a back and front garden to aid water drainage and reduce flooding risk.
*Reduce number of houses and / or density of houses to ensure endangered wildlife is protected
*Ensure houses have sufficient parking. Modern developments seem to assume one car families and thus causes congestion on the roads outside.
*Build key infrastructure in advance of allowing new building to prevent construction traffic going through existing road network pinch points.
*Funding to extend the library and community centre.
*Work with rail and bus providers to ensure that services are increased rather than reduced (see Great Northern 2018 consultation).
*Increase the size and amenities of the station (i.e. more manned ticket office hours, possibly more parking)
*Rather than build as an extension of Baldock should the Council not consider developing a town of the same size away from existing communities in order that the road network and other infrastructure can be developed from scratch and thus be suitable for the needs of the community rather than exacerbating existing infrastructure issues? This has worked successfully in a number of places, such as Milton Keynes.

Site BA2 & Site BA3 & BA4:
Objection to the proposal on the following grounds -
*Informed that the first build will be in site BA2 and BA3. As a result there will be pressure on the current schools, doctors surgery and other amenities such as the community centre, library and town centre parking. There is no mention of providing additional school or doctor services within the current plan for BA2 and BA3. This also applies to BA4.
*Currently, there is one doctors surgery servicing Baldock and surrounding villages (Ashwell, Weston, and Sandon). It is difficult to secure a same day appointment if you ring 10-15 minutes after the opening time. Advance appointments usually entail a two week wait.
*The current primary school provision in Baldock consists of two faith schools (St Mary's and St John's) and 1 non-religious school (Hartsfield). Hartsfield has been oversubscribed for the last 4 years and has a catchment of only c.900m. Many in Baldock have to travel to village schools (Sandon, Ashwell, and Weston) incurring traffic and timing issues for working parents. The new 495 combined builds will generate at least another class worth of primary school children with nowhere to go and yet it is already significant problem.
*Limited parking available at Baldock railway station. Also, increased commuter traffic would put further pressure on already congested junctions such as the A505/A507 crossroads.
*No mention of what % green space will be provided, nor mention of tree planting to improve air quality, nor mention of parks for children.
*All construction traffic would need to go through the town causing air quality, noise and congestion issues.
*Without new parks and green space, people in the new sites would need to drive to the existing facilities causing congestion and air quality issues.

Suggested changes to the plan:
*Additional primary school provision along with the new builds at sites BA2, BA3 and BA4 to cater for both the sites and the current children of Baldock. This to be available and online at completion of first phases of building.
*Recommend a variety of housing styles and increase the allowances of self-builds; this will reduce the monotony often associated with a housing development.
*Require each site to include a children's play park.
*Require a minimum of green space per site to ensure improved air quality, surface water drainage, and general aesthetic wellbeing. Suggest developers imitate the % green space achieved in Milton Keynes, a highly successful build with regards to green spaces. 22% figure 1.7, pg 22 in the MK planning manual, MKDC 1992.
*Every house to have a back and front garden to aid water drainage and reduce flooding risk.
*Additional railway parking
*Additional town centre parking
*Funding to extend both the library and community centre
*Work rail and bus providers to ensure that services are increased as the size of the town grows rather than reduced (see Great Northern 2018 consultation).
*Increase the size and amenities of the station (i.e. more manned ticket office hours)
*Ensure houses have sufficient parking. Modern developments seem to assume 1 car families and this causes congestion on the roads outside.

I am writing to object to the NHDC Local Plan.
3,500 houses will bring even more congestion and air pollution to Baldock's roads, mostly Station Road/Whitehorse Street/Royston Road & Clothall Road, which are already over used and polluted.
There is also the over crowding off our Doctors Surgery and local schools to consider.
Obviously we do need more houses in Baldock. 500 to 1,000 could be built on the Clothall Common with a link road to the A505 would be ideal to carry traffic away from these busy roads.

To build so many houses NE of Baldock up to Bygrave seems a little excessive, to say the least!
The need to provide more housing for the UK is understandable but let's be proportional about this. Thirty odd years ago a Baldock northern bypass was thrown out because of unsuitable sub soils in the area yet now you're proposing to build houses on the same land - not a good idea I would like to state. Further, planned infrastructure is far from suitable for so many more residents for the area.
I suggest you give these plan some very careful consideration.

I am writing about the house building in Baldock, personally I think the suggested amount is to much, I agree maybe 500 on Clothall would be enough no more, the town doesn't have the infrastructure for this amount of houses schools already over crowded so would need 2 more nursery's, 3 infants and junior schools and a bigger secondary school already the land is nearly all built on, let alone the roads and traffic issues this may cause when building houses and more roads. The town also doesn't have enough employment to sustain this amount of houses.

I am writing to express my concerns about the proposed build of 2,800 new homes on land to the north of Baldock; I have referred to the Proposals Map.

My concerns are as follows:

This proposal will place the existing infrastructure in Baldock under increased pressure in terms of volume of traffic, use of local amenities including schools, access to General Practitioners and shops. Baldock as a town is thriving but only because it is able to support the community in its current state. There are sufficient shops in the town but there is additional traffic due to Tesco which produces a burden on the local community not only because of taking business from local traders but also because of volume of traffic. Adding more houses to Baldock will only place further pressure on traffic.

From an environmental point of view, I find it hard to imagine that this new housing development won't have an impact on areas which should be allocated for conservation and we should protect greenfield areas. Baldock has easy access to greenfield areas and surrounding villages, I foresee that this access will be prohibited if building occurs on these greenfield sites.

The building of these houses will only cause further development of Baldock from a rural market town to a more built-up area which will impose burdens on existing traffic flow and the ability to access areas of natural beauty.

Finally, we need to learn from past mistakes when the perception is that new houses are needed when the building on brownfield sites has not yet been exhausted. We should cherish what was farmland and green areas to provide a mixture of rural and town. This proposal will mean that we no longer have the choice of both. Baldock is a lovely town and has many assets not least the ability to walk only a short distance to fields grass land.

Creating a new infrastructure will only serve to divide the town and place pressure on the existing infrastructure.

Please keep Baldock as it is without the need to create another community in the town.

My main objection to the building of houses up the Bygrave road is the traffic. It will grid lock into and out of Stevenage, where I work, in the Old Town, I also feel there has been enough development, outside of towns, locally, that we have a duty to keep places of outstanding natural beauty. Bygrave needs to stay separate from Baldock, what's to stop the houses going all the way to Ashwell, other than a will to take care of our countryside for future generations? I feel very deeply that this is a wrong move. Also that there is land between Letchworth and Baldock, as well as within both towns, better suited to development.
I have always worked locally. Traveling in all directions, never more than a half hour drive from Bygrave. From here it is a twenty minute drive, that can take three quarters of an hour, to an hour, between 7.30 and 9, into Stevenage Old Town, in the morning, at the moment. Now, this week, last week. That's with taking the white farm road from here to there 505, not the conventional journey through Baldock. The return journey can be as bad, however, like many who are retired or do not work, I usually drive home out of 'rush hours' time. Please make a decision based on working people's experience, as we are the folk living here. Whatever road development is done, cars will fill it. It is impossible to alter the bottle neck into Baldock, from Stotfold.

I have lived in Bygrave most of my adult life[...].
I came here because this was the most beautiful place I knew, to live and bring up a family, we moved my pony here. I still ride these lanes, with much less safety, constant traffic.
Like many others, I make the most of the bridle ways, that will become unusable, the cyclists and walkers too, will struggle against the surge of buildings and traffic. The very people invited here to live will not be able to enjoy the countryside for fear of being run off the road by inconsiderate drivers.
As a lifelong painter, the gentle slopes out of Baldock are inspirational. I have ridden through this landscape for over 40 years, can remember, long before that, seeing the view from the seat beside my parents, in the sidecar on dads motor bike. The back of my mums bicycle as a baby in the 1950s. We all feel the same sense of awe as we leave Baldock.

If you build up to Lower Bygrave from Baldock you will be responsible for putting an impossible strain on the roads. Letchworth, Baldock, Stotfold, Royston and Stevenage commuters will increase, accidents will go up, Baldock Station will be unable to cope, along side all other recourses, schools, water, refuse collection...it has happened already in Great Ashby in Stevenage.

That's without the drainage problems, caused by building on the clay. My pony field has flooded, the last few years, as a result of a garage, one garage, being built.
Please look to other infill possibilities and leave our beautiful down land alone.

Thank you for your time, I hope you can be impartial and have no personal gain to be made out of developing our countryside, as this is a decision to change an historic landscape for ever, as well as making our lives, and our children's lives, more difficult.

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

We fully appreciate that more houses need to be built, however it's the inequitable scale of the proposal that's so wrong and unfair. Addressing the new housing need of the whole of North Hertfordshire by almost doubling the size of Baldock; in virtually one location, on green belt land, is clearly the wrong way to proceed. The impact on Baldock and surrounding villages is simply punitive.

I will leave it to others with more knowledge of Baldock to outline the issues relating there and instead comment here on the impact of traffic to Bygrave. Air pollution is is one of the biggest killers in the UK, estimated to shorted the lives of 40k per year [BBC Feb 2016]. Bygrave already suffers from close proximity to the A505 (approx 1000m to the east of Bygrave) which is bearing increasing traffic flows as housing and industrial developments expand in Royston, Cambridge and surrounds. The noise and pollution from A505 traffic will only increase.

The proposed Baldock housing development will create extra traffic: approximately 5600 extra cars. This is estimated on 2 cars per new development household. I understand this excludes service vehicles.

The traffic will disproportionately impact Bygrave who will suffer increased levels across 3 sides: east via A505, south and west via the new road circling the development (connecting A507 to A505) and finally through the middle of Bygrave on the existing road going from Baldock to Ashwell. It will be horrendous during rush hour and unfortunately there'll be little relief at weekends because the road through the middle of Bygrave accommodates social traffic going to Ashwell and surrounding villages.

Bygrave is a quiet, rural village in green belt land with the majority of houses lining the Baldock -Ashwell road. It's tranquility is already threatened by noise and exhaust pollution from the A505 impact; especially on a easterly wind. The excesses of proposed development will have a serious and damaging impact on the quality of life of the people of Bygrave.

I should also bring to your attention the newly built Bygrave Lodge Aerobic Digestion plant. This generates electricity from rotting waste. Whilst efforts are made to reduce the stench of the feed, it is often the case that odorous smells (and it can be a nauseating stretch) get blown along the A505 to the Baldock junction and surrounding fields. In this regard I question the suitability of some of the more northern plots of the proposed black horse farm development.


Proposed changes to plan:

1. Significant reduction in the number and density of houses in the black horse farm development.

2. Compel NHDC to sell the land at a price that enables lower density quality buildings rather than at a price where the highest bidder can only pack the place with soulless boxes as a way to make a return on investment. Likewise to ensure a large portion of self-builds to add character.

3. Make the proposed road connecting A505 and A507: 1) A road having a 20mph limit with speed bumps. This will ensure it's only used for residential purposes rather than a rat run between the two roads. BTW the A505 and A507 are adequately connected where they meet near Letchworth. 2) To be a road situated in a deep cutting, that benefits from significant tree planting and connecting to the A505 via a tunnel under the railway line.

4. To provide significant noise protection to: 1) The A505 from the Baldock junction to that of Slip End aimed at protecting Bygrave from increased noise levels. 2) Bygrave residence close to the Baldock-Ashwell road.

I do hope you appreciate the issues raised. Please do not be tempted to rubber stamp this historic case study in planning mis-management.

I write to register my disgust at the scale of new homes planned for such an historic old town! Though I am not against some being built, it is clear that the planning committee are not of sound mind or common sense, looking at the vast settlement planned. Taking green belt land at will is not acceptable, or compatible with the size of facilities available in this area. Has the old habit of back handlers reared its ugly head to promote such a scale of country side devastation? It is also stated that the fast rail link to London be cut?!? With a proposed 6,000, more commuters, somebody is clearly loopy! The estate at Larkins Close, can easily be extended, and further housing to the back of Salisbury Road. This would take an estimated 1,000. homes which could extend perhaps to a little more, with Norton Road School taken back for education. I think the new estates should end no further than the last farm houses on the Bygrave Road. This would leave our ancient village intact, and room to vacillate the flow, with new sites allocated on the other side of the AI motorway. Planners are supposed to be creative people, that is why they choose such a vocation. Not have a bad day and lump everything together, because they cannot bother to think or even consider the effect of their weak efforts, on the environment or people affected by such poor judgement! I should like a reply to this letter, and to know the person responsible for such poor efforts. Also I register my dismay at the lack of thought these councillors have for such a sensitive issue, which will not be taken lightly by any of the Bygrave residents now or for years to come.

I wish to object to the massive and totally inappropriate development to the north of Baldock as proposed in the North Hertfordshire District Council's Local Plan 2011 - 2031 (Proposed Submission, October 2016). My objections are based 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."

The Local Plan fails to meet the requirements of the National Planning Policy Framework and the planners have largely ignored residents' concerns about local amenities and the proposed development plan.

1. Traffic congestion through Baldock
The main traffic issue is where the junction 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. The junction is always congested, and during the rush hour in the morning and evening, can extend back almost as far as the Baldock services. The proposed new road connecting A505 and A507 wouldn't be enough to accommodate the additional traffic for the proposed development and would only add to the problem we already have.

2. Access to Baldock train station
During the rush hour, cars from the station often have to force their way into the traffic coming into Baldock. Turning right at the bottom of the road at the station is a particular problem. Additional commuters would cause even more congestion.

3. Lack of local infrastructure to support existing needs of the town and it's residents.
The scale of development around Baldock will place massive additional pressures on schools, doctors' surgeries and other basic amenities which are already at overstretched and full capacity. The new houses would be built before any additional facilities would be in place.

4. Development of the Green Belt

NHDC councillors have stated that they are forced to propose green belt developments in order to meet government housing targets, but the ministerial guidance on Green Belt development published on 6th October 2014 makes it clear that councils are NOT required to build on the Green Belt in order to meet housing targets. I feel very strongly that we should be doing everything in our power to protect the Green Belt - particularly since there are other sites available that DO meet planning criteria and are NOT in the Green Belt.

The scale of the proposed Blackhorse Farm development is well beyond anything that Baldock could reasonably be expected to accommodate. The very large number of houses proposed and the additional traffic which would be generated would be completely detrimental to the town. The planners have not described the Blackhorse Farm development as a new town but that is what it would be. Sensitive infill development in appropriate areas of the town would be beneficial, but the urban sprawl that is proposed will lead to massive traffic congestion and make the town centre almost inaccessible to residents and the surrounding villages.

We moved into our new house in a small development in Baldock 4 years ago. The town which is steeped in history has a real sense of community with local shops, eating places, churches, schools and doctors surgery. Traffic is an issue at the moment but I cannot imagine what the future holds for this small market town should this proposed new development go ahead.

I would urge all those who have the power to limit the amount of new houses allocated to Baldock to reject the proposed plan so that the character and heritage of this historic market town can be retained.

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.

Environment Bank welcomes the opportunity to briefly respond to the Consultation for North Hertfordshire District Council's Local Plan 2011-2031 Proposed Submission Draft. We support Policies SP12: Green infrastructure, biodiversity and landscape, SP14, SP18 and SP19, along with points 4.76, 4.185, 11.38, 11.39 and 11.48, and their requirements for No Net Loss / Net Gain of biodiversity, metric assessments of biodiversity impacts and offsetting to deliver compensation.

About us:
Environment Bank is a private company working to broker biodiversity compensation agreements - offsets - for developers and landowners. We act as impartial advisers to Local Planning Authorities and are experts in biodiversity impact assessment and No Net Loss (NNL) strategies. We have partnerships and support relationships with over 25 LPAs across 15 counties - providing advice on local policies, planning guidance and strategies, together with support in implementation and individual planning cases. We have seen biodiversity No Net Loss, Net Gain and offset policies be adopted in Local Plans across the country.

Working on individual developments on behalf of developers and planning authorities we calculate the biodiversity impacts and enhancements of development proposals using approved Government metrics, determining residual biodiversity losses, if any, and proposing offset solutions. Our ecological experts then match a developer's compensation requirement with sites put forward by landowners and conservationists who undertake biodiversity enhancements on their land to generate conservation credits available as compensation. Offset schemes must be the right type of site, of the right size, in the right place, at the right time, for the right cost. Credits are sold in exchange for the creation or enhancement of habitats, generating biodiversity gain. Thereafter, legal and fiscal systems assure planning authorities that such compensation measures have been arranged independently and delivery will be overseen and guaranteed in the long-term, providing net biodiversity gain across a district.

Although I understand the requirement for continued and additional housing in all communities I do not understand how Baldock including Bygrave and associated communities can be the subject of such a large designation proportionately to the remainder of North Hertfordshire. In fact North Hertfordshire is virtually one conurbation as it is with very little space between each town now and really none of the areas should be considered.

Land Ownership in Bygrave: Hertfordshire County Council own all of the proposed development land and because of this are using their weight irrespective of the local community to pander to Government pressure. HCC are rein-acting the folly demonstrated by previous governments in getting 'rid of the family jewels'. This land should be considered as money in the bank for future generations and not a quick fix for the next few years.

Locality: Baldock is a small historic market town and Bygrave a small village also with its own history. These two will in essence be merged as one which will then destroy the individuality of both settlements.. Clothall Common was a new build 'add-on' community to Baldock - not considered a success in integrating the area into the town. Any expansion to Bygrave area -Black Horse farm site - would inherit the same issues. The proposal of adding 2800 houses + schools + community centres would destroy the current nature of the town and village.

Land: The Government has always indicated that brown field sites should be earmarked and that green belt sites should be avoided where possible. The Government stipulates that green belt should only be rolled back in exceptional circumstances - once lost never retrieved. This has been confirmed in a letter signed by The Rt Hon Eric Pickles MP DCLG to a question submitted by Peter Lilley MP. I have not seen anywhere where this area is deemed an exceptional circumstance. The green field sites earmarked for the Baldock/Bygrave development are good quality farm land and it is again government & EU edict that this should be utilised and encouraged to continue producing crops for the ever growing population and ever important that this be used locally - several farms are under threat with these proposals. They have been tenanted by families for many years. Any compensation offered to these families will never be adequate for the loss of their homes and livelihoods. The area has views over the countryside of natural beauty from all directions which would be lost and is an important habitat for foxes deer and badgers and other wildlife.

Infrastructure: There would need to be a major review of all services. Bygrave has suffered a number of power cuts and the water supply has been a major issue over the years. Should this development go ahead when would these and other required facilities - schools doctors surgeries etc be provided. If funded by the Developers this will not be carried out timely as they would want to fund from profits of homes sold. When challenged at local Council meetings there has been no response that these have been adequately considered and is not consistent with the requirements of national policy.

Transport

The railway transport system is almost at capacity now and the Operator has just announced that services to Baldock will be reduced. In addition parking at the station would be undersized and the costs charged prohibitive for many to use even if made larger.

Parking in town is to capacity.

There is a plan to construct a road over the railway linking the A505 to the Great North Road A507. The Great North Road is to capacity at peak times in both directions. There is also the consideration of air, noise and light pollution of this proposed road. This will be totally unsustainable There has been no detail given as to how this will work

The Great North Road links with the A1 the major road into London. The road in peak times is to gridlock and can take up to an hour to pass the Stevenage bottleneck already. In addition the Great North Road into Baldock is also at capacity at peak times and joining from the Ashwell Road difficult. We are told by Highways that lorries cannot be rerouted to Letchworth to join the A505 as designed. This road will be horrendous both during construction and incapable of taking the extra load on completion of the proposal.

Utilising the figure of 3290 additional homes there will be approximately 7000 additional cars each with a minimum 2 movements per day giving additional journey movements of 14000 per day this will be unsustainable and I believe will massively increase air pollution to the area and Baldock particularly as it sits in a valley.

People:

I do not believe that the population of Baldock and hinterland is growing at such a level that determines such an invasive expansion. Therefore the obvious answer is that it is proposed to move people into this area. Little consideration has been given to where such a huge number of people (say minimum of two per household x 3290 = 6,500 - 7000) are going to work and play. Certainly there are not the jobs to sustain this number so all will be travelling out of the area.

Conclusion

The plan as such has been formulated to a point and falls short that information is not available to the residents of Baldock and that in itself is not consistent with national policy. It is understood that Henlow Air Base will be available shortly for development a far more suitable area for expansion that will affect less people instead of the panic that is being demonstrated by the Local Plan. I trust that the above is used in making the final decision to give historic Baldock and Bygrave the future that it warrants

I am writing with concern to the proposed plans for the development of housing in Baldock. Whilst acknowledging that extra housing is necessary to meet the needs of the local population I must question the disproportionate number of new houses in Baldock compared to other areas in North Herts and the justification of the plans.
Concerning BA2 and BA3
There is no mention of providing extra provision for the increase in numbers arising from the 400 houses proposed, requiring registering at the only doctors surgery in the town. It is very difficult to book a same day appointment, unless you are lucky enough to get through on the telephone in the first few minutes of opening time. Long term bookings are at a premium and similarly difficult to secure, usually a two week wait.
There is no reference to school places for this stage of development. Currently there are two faith schools and one Primary school which is oversubscribed. The new houses will surely generate the need for extra places to be provided.
There is no reference to the planting of extra trees, the lungs of a community, as well as being of an aesthetic value. Do not the residents deserve a quality environment?

Concerning site BA1
The road network is already very congested at peak periods and this is exacerbated when either of the by passes are closed in times of emergency, which is not infrequent. As there are few opportunities within the town for employment, to which people might walk, it follows that the extra population will need to travel beyond the town. This will be either a rail or road journey.
There is tremendous pressure at the traffic light junction where the A505 and A507 meet. The tail back queues are a reminder that the junction cannot cope with the existing demand. This is an historic situation which has failed to be resolved due to the fact that the properties at this junction are listed. The impact on people who need to arrive in Baldock for work or school is significant and I have personal knowledge of a shop manager who has failed to open on time due to being held up in this traffic for up to an hour. The proposed mini roundabout (AECOM Table 5.1) will not resolve the congestion that already exists and therefore will not cope with the added volume of traffic.
If, as frequently happens the railway bridge with a head height of 14'6'', is struck by over height vehicles, then the congestion is severely impacted upon. The increase in traffic will only add to the probability of this occurring more frequently.
This road is not capable of carrying the current volume of traffic and as the IDP Traffic Baseline (para) shows that traffic in North Herts will go up by 16.1% anyway then the building of extra homes in this corridor is surely unjustified and not effective.

I am very concerned about air quality in the town; Baldock is located in a valley and consequently air circulation is not good. The volume of existing traffic means that there is a high level of emissions. The invisible ultra fine particles, PM2.5, emitted by diesel engines are a major risk to health as they penetrate the lungs and circulatory system. This increases the risk to the health of our children, the old and the vulnerable and in fact, to the whole community. It has been reported that prior to the Baldock By-pass being built in 1995, the levels of asthma in local children was well above the national average.
One only has to walk along Hitchin Street or Whitehorse Street at the beginning and end of the school and working day to be aware of this. In fact the levels are close to exceeding EU permitted levels (para 9.28). The housing and Green Belt background paper informs us that site 209E was considered unsuitable for these very reasons. Is not the quality of the air for Baldock residents not of equal value? The increased volume of traffic can only add to these levels. For this reason alone the plan is unjustified.
The plan is unjustified and not effective as there is not an adequate highways structure to take the extra traffic that will come with the development. Both vehicular and pedestrian, currently the A507 /Bygrave Road junction has poor sight lines when accessing the A507 from Bygrave Road, a significant increase in vehicular traffic onto the A507 will increase the accident probability at this junction; Bygrave Road is not even classified as a B Class road; the width of the road is not sufficient for safe passage, together with the blind bends, lack of pedestrian footpath along the rural section all add up to an inadequate facility, which would not be funded by the developers at the outset as the infrastructure aspects are always funded from housing receipts in retrospect, invariably resulting in a reduced scope, if at all!
The existing station is very small and there are proposed cuts to the existing train services by Govia. It appears that this company were unaware of the proposed development. Many people commute out of Baldock and the proposed development would significantly add to the volume of traffic entering the town. The car park is already limited and many commuters park in the surrounding residential streets. This has an impact on domestic parking. No provision appears to have been made for the extra parking spaces that will be required.
There is also no reference to provision of extra play facilities. Although some do exist within the town they do not have car parking provision, the BA 1 development will be too great a distance for young children to travel to enjoy any of the existing sites. Children need to have safe areas in which to play and exercise. There are already signs of obesity amongst primary children (in my professional role as a teacher I have seen an increase in such cases). We cannot deny them this essential facility.
No consideration appears to have been given to the natural environment and the fact that the area is home to several endangered species including the corn bunting, pipistrelle bats and newts. It is our duty to protect these species, not further add to the destruction of their habitats.
There is no modelling of the impact from the new developments on the infrastructure (AECOM section 7 summary). The Local Plan Viability Assessment (update 2016) has not considered specific infrastructure pressures and mitigation concerns associated with the major sites especially the BA1 site.
Drainage is also a concern; as Baldock sits in a valley, flood risk could potentially be high. During recent heavy rainfall, the town has suffered flooding with St Mary's school suffering several times within a few weeks as the drainage system was unable to cope. This caused severe disruption to the school. A significant increase in hard landscape due to housing will always increase the rate of flooding (especially if the required infrastructure is not in place), the infrastructure in Baldock does not have the capacity for additional storm water or sewage treatment.
Baldock has a thriving community, we as residents; enjoy a good quality of life. The proposed expansion will irreparably damage the unique feature of this historic market town. Surely we should be preserving our heritage for future generations; it is their right to inherit this and ours to protect it for them.

We would like to say at the outset that we understand the need for a Local Plan and the national need for more house-building. However the Local Housing Plan for North Hertfordshire, as proposed by NHDC, is, we believe flawed in many respects.

Unequal division of housing allocation
Some building has taken place in Baldock over the lat few years, but NHDC now proposed to increase the size of Baldock by 3,290 homes by 2031. This will double the population of the town. Baldock is the smallest of the towns in North Herts but is now required by the council to have more housing than each of the other three larger towns of Hitchin, Letchworth and Royston. The main reason for this seems to be that all the land proposed for the new development is owned by Hertfordshire County Council who are willing to see it for this purpose; therefore NHDC do not have to contact individual landowners asking if they would be willing to sell.

Many people have said that the number of houses stipulated to be built in Baldock could easily be contained in a new town situated elsewhere in the County. NHDC say they may well have to consider this in the future, but that there isn't the time now to do that now.

Previous emails
I also append copies of two emails sent to NHDC at previous consultation stages, which we would like you to read, but would also like to add the following.

Infrastructure
We are particularly concerned about the developments BA1 and BA2/3. With developments of a certain size eg BA1, infrastructure will be provided eg schools, doctors, dentists, shops etc, but with smaller developments ie BA2/3 infrastructure will not be provided so no new schools, doctors, dentists etc.

We are particularly concerned that insufficient thought has been given to schools; provision. The three Baldock primary schools are currently over-subscribed so that Baldock children, even those living within walking distance of the schools, now cannot be accommodated an so have to be driven to local village schools eg Sandon and Ashwell.

It is already difficult to get a doctor's appointment so this will also be adversely affected by such a large number of new homes.

Traffic
The centre of Baldock consists of just four main streets with very limited parking. Three-bedroom houses are now allocated two parking spaces each; if just a fraction of new householders want to use the facilities in the town centre at any one time, then we foresee enormous problems.

Railway travel
The number of commuters on the local line into Kings Cross is growing all the time as more houses and apartments are being built. GOVIA are currently planning to reduce the number of fast trains stopping at Baldock and are in the process of a consultation period. Our councillors have been in touch with GOVIA who, apparently, had no knowledge of this proposed local plan but have said they will review their decisions regarding changes to times of trains from Baldock. However, even if the trains remain as now, journeys will become more difficult and uncomfortable as people already have to stand on their journey to Kings Cross. Many people moving into the new houses will inevitably be commuters so this will only exacerbate the situation.

Sporting facilities
We are all encouraged to play more sport and be more active, but according to Baldock Town Football Club's figures, Baldock's current leisure facilities are 60% for adults and 40% for children below the national average. So, when infrastructure is being planned we believe that land should be set aside for providing more leisure and sporting activities for the whole town.

Nature Reserves
We currently have two nature reserves in Baldock: one on the Weston Hills and the other at Ivel Springs. Access to these and the wider countryside is vital to people's well-being. Residents need to be able to relax and benefit from contact with nature which is proven to reduce stress. So, parks and green areas within new settlements is vital as well as easy access to the wider countryside. We also need to preserve green space between us and other settlements (towns and villages) and so a large area of designated nature space between Baldock and Bygrave, for instance, would be beneficial and aid the well-being of both the people in the town and natural habitats.

Below are Emails sent to NHDC at various times during the consultation period.
Since writing in November, many people have supported the idea of a separate development elsewhere in the county with its own centre and identity, where there could be shops, pubs, schools, doctors and dentists' surgeries, new roads etc, built on 'Garden City' lines. One such development is, I believe, proposed for a disused airfield in Northamptonshire, where 1,000 houses are proposed. If the authorities in that area think that 1,000 new houses justifies a completely new and separate development, then surely a development of 3,591 houses should have the same claim. It was distressing to hear Cllr Andrew Young admit (and he was only being honest) that initially there would not be enough school places for all the children living in the proposed new homes, but he wanted to reassure parents that their children would be transported to those schools in the area where there were places, be it Letchworth, Hitchin or Stevenage. No parent wants this for their child. Precious, but delicate, friendships are formed at these young ages and it's good if those friendships can be carried on out of school, so obviously if all children go to schools in their own town, they will be able to socialise after school and at weekends. It is not so easy for working parents to keep transporting their child to other towns all the time.

The proposed development of 3,591 houses is almost four times the size of the Clothall Common development and it would be difficult to integrate people living in those houses into the community life of the present town. When the houses started to be built on the Clothall Common estate, people in the 'old town' maintained that everything should be done to integrate it into the existing town, so not have separate small shopping precincts, nor village halls nor pubs, but that there should be an active desire to integrate people there with the current Baldock residents. Over time this has happened, with people living on Clothall Common taking part in activities in the town, joining organisations and helping run the social and community life of Baldock.

We cannot hope to do this with a settlement four times the size of the present Clothall Common development. Much more sensible would e a new development which had its own identity and could have shops, community halls and maybe even a pub. People like to have an identity and to feel part of something and belong. It helps a community coerce and I believe that because people in a small community quickly get to know one another, it deters crime. Youngsters can be given a place where they can meet and again make them feel a part of the community. As I said in my previous email, this isn't NIMBYism but trying to come up with a workable solution, not just for the present residents of Baldock, who will find life difficult with more traffic and more demands on school places, doctors, and dentists etc, but also for new people coming into the area.

This idea has also been mooted by our three local MPs: Sir Oliver Heald, Peter Lilly and Stephen McPartland. Cllr David Levett says in a report in the Midweek Mercury that '... longer term this idea should be pursued ...' Why not now? Why go for a quick fix solution because it is easy for planners at NHDC and joyful for Herts County Council who own the land?

I don't fee that NHDC have fully investigated the possibility of building a small 'Garden City' development elsewhere because it would take too much work to approach landowners to see if they would be interested in selling their land to developers. It is so easy to accept HCC's offer as they conveniently own nearly all the land around Baldock.

We would also go back to the statement made by Cllr David Levett at the public meeting at the Leisure Centre when he said that this is a 'far from perfect plan'. Is NHDC not ashamed to be putting forward a plan that is 'far from perfect'. How on earth can anyone support it? We really do think that NHDC needs to think long and hard about this. They say they have to come up with a plan and this is the best one, or the developers will move in and they will have no control on what is built. But surely everything has to have planning permission, so they do have some control. However, to prevent that happening, it seems to many people that the best solution is a completely separate development - and preferably not on Green Belt land that is also valuable agricultural land.

We have also seen the letter from the Council for the Protection of Rural England who express grave concerns about the Proposed Plan. We would urge you to take all their points into consideration. We were particularly interested in their quote from the Planning Minister to the Chief Executive of the Planning Inspectorate: 'We have set out in our recent guidance that a Strategic Housing Market Assessment is just the first stage in developing a Local Plan and councils can take account of constraints which indicate that development should be restricted,' also: a SHMA is untested and should not automatically be seen as a proxy for a final housing requirement in Local Plans.' (my underlining). I think this does then give all councils more leeway than we have been given to understand and maybe more leeway than they realise.

Finally, on more than one occasion, we have been told that if we do not accept this plan with the number of houses involved, then developers will simply be able to move in and build what and where they like. In the letter from the CPRE it would appear that actually that is not the case at all. So it looks to us as though there has been some scare mongering.

Please see below copy of original email sent in November 2014:

Dear Sirs

We feel very concerned about the size of the proposed development around Baldock. We understand that 3,500 houses are proposed for Baldock, a much higher number than for any of the other towns in North Hertfordshire. It is this inequality that incenses the people of the town. We appreciate that new houses will have to be built to accommodate the ever-growing population of this country - and it would be good to know that those who have families locally could buy houses nearby if they choose, but we feel that a development of this size would be detrimental to the town.

At the moment, Baldock works very well as a small community - everyone says what a friendly place it is and the amenities we have currently serve the town well - just. A new development such as this would put overwhelming pressure on schools, roads and NHS services. Hertfordshire County Council, who own the majority of the land that would be required for the proposed development, have said that there would be no problem with the infrastructure - they would manage that. But these houses will be built over a period of years up to 2031, so we cannot imagine that new schools, doctors, surgeries etc will be built in Phase 1 of the development. So families moving into the area will naturally want their children to go to Baldock schools and the families will want to use local doctors and dentists. This will not only affect people in the new houses but also current residents, who will find it increasingly difficult to get appointments.

One of the reasons Baldock works so well is that although we have three primary schools, the majority of those pupils will end up at Knights Templar School, immediately forming a cohesion for the town of the future. We know so many people who went to Knights Templar when our children were there who have stayed in the town because they like it here. They like the amenities and the lively 'small-town' feel of the place. This is not something to be dismissed lightly. It may well be one of the reasons why Baldock has such a relatively low crime figure.

At the meeting at St Mary's Junior School when many fears were expressed about this proposed development, someone who had worked for Anglian Water expressed real concern that the utilities - and particularly the water supply and sewerage disposal - wouldn't be able to cope. Electricity and gas supplies are also a worry. We already hear rumblings that if we have a severe winter there might be power cuts.

When the bypass was built, for a short time, the number of cars and lorries coming through the town was noticeably less. However, volumes have gradually built up and at times queues of cars can again be seen in the town. How on earth will the town cope with all the people and cars living in another 3,500 houses. Presumably they will sometimes want to come into the town to shop - particularly as we have a large Tesco in the town. It is understood that new roads will be built connecting a new estate to the bypass and this could, in effect, then produce a satellite town with little connection to Baldock. Why not then build a separate town, with its own identity elsewhere. This is not nimbyism, but practicality. Obviously the fact that Herts County Council owns so much land around the town is an attractive proposition and an easy option.

There is also the fact to be taken into consideration that so much agricultural land will be used up. We are told we need to grow more of our own food, but with agricultural land being snapped up for housing how is this possible? We feel that the whole question of how much housing is being built in the South East needs to be looked at, but recognise that this isn't something that NHDC or HCC can do. However, we do believe that they can question the government as to its quotas for the South East. If HS2 and HS3 rail links are put in place, then in 20 or so years time the north of the country might be more attractive both for people to move there and for people currently living there to find it a more attractive proposition to stay there rather than to move to the over-crowded and over-priced South East.

Even if the 12,100 homes proposed for North Hertfordshire were to be evenly distributed between the four towns in North Herts and the villages, we would probably be looking at getting around 2,500 - still a great number, given the current size of Baldock - probably another half a town. We urge you to think very carefully how you allocate this housing, both for the well-being of the current population and those who might wish to move to the area.

We apologise for the length of this email and, if you have managed to read it to the end, thank you for doing so.

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We are writing to express our views about the Proposed Submission North Hertfordshire Local Plan 2011-2031.
Baldock is a rural, historic market town, the smallest town in the region, with more listed buildings than any others in the district. It has around 5,000 dwellings. If we get the proposed 3,590 more dwellings that would equate to a massive 80% increase. We feel this is a disproportionate increase that will adversely affect the nature and character of Baldock (see Green Belt section below). Also large settlements on the edge of the town with their facilities and local shops will compete with the existing shops and fragment the town; the heart of Baldock will be lost.
We should be thinking regionally and working co-operatively with others and with our neighbours. Houses do not make a community and a huge settlement of 2,800 as that planned for Blackhorse Farm is not viable. We need to find a suitable site for a new garden city. Baldock should be grown and expanded organically, not exponentially.
We have focussed our objections below on BA1, the Blackhorse Farm development, but many of these should be applied to Baldock in general.
Green Belt
The plots of land around the proposed Blackhorse Farm development (BA1) are all green belt. The NPPF government guidance states that green belt boundaries should only be altered in exceptional circumstances (para 82). There are none in this case. Green spaces around towns are crucial. The North Hertfordshire Green Belt Review states that these particular sites make a 'significant contribution' to the Green Belt purposes. It is short-sighted to simply move them to another area in the region. It is an essential part of the quality and character of the area and a fundamental part of the town's design. It should be protected. It enhances the high quality of life that people in the area currently enjoy.
The Blackhorse Farm site is an area of rolling countryside. A development this size would have significant adverse visible impact on the landscape. Once it has been built on, it is gone for ever. The NPPF states that the essential character of Green Belts are their openness and their permanence. They 'preserve the setting and special character of historic towns'. The development would also have a negative impact on the Ivel Springs local reserve and wildlife site. The sites around Bygrave Road are teeming with birdlife. Since 2012, there has been a large flock of resident starlings as well as house sparrows, finches, linnets, tits, pheasants and sparrowhawks.
This Plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. West of Stevenage should be reconsidered.
Road network
There are considerable existing congestion issues both locally in Baldock town and also on A1M. The current bypass was built and still there are continuing traffic problems with static traffic jams during peak travel times. With the new roads proposed to take traffic onto the Royston Road there will still be many commuters needing to travel through Baldock. The increase in the weight of traffic will cause further gridlock and put terrific strain on the road network. We already have a dangerous bottle neck under the narrow railway bridge in North Road where two people are unable to pass each other on the pathway and there are road safety concerns at the exit from Bygrave Road onto North Road.
Lorries are still adding to congestion problems by using North Road to access the A505 rather than using the bypass. How many times have lorries struck the railway bridge, despite the 'low bridge' warning? Many times, we have seen lorries inch through and only just clear the bridge. All of this delays traffic, especially if there is a bridge strike.
(In addition, the current weight limit of 7.5t in Bygrave Road would be insufficient for heavy plant vehicles used during construction).
The proposed new development on Blackhorse Farm relies on a new road bridge being built over the railway. We understand that Network Rail have no knowledge of this proposal; an assumption has been made where it is not clear if this is would be possible.
The A1M between junction 6 and 10 is unable to cope with the current capacity travelling during rush hour and changes are being put in place to try to alleviate this problem. But many houses are being built in Royston and more are proposed in the North Herts Local Plan which will all impact on the A1M corridor. It has no capacity to take more traffic.
The NPPF para 32 states that all developments that generate significant amounts of movement should be supported by a transport statement'. The proposed North Herts Local Plan refers to 'travel plans' on page 89 and 'measures to include' on page 61 but there are no details.
The Plan is not effective as it cannot be delivered in the plan period. It also fails the consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work.
Transport
The Plan makes no significant points other than the convenience of Baldock's location next to a station. The current train arrangements would not be able to cope with the proposed influx of new commuters not just at Baldock, but also from all along the Royston/Stevenage corridor. We understand that longer trains are proposed for the route, but the platform at Baldock will need to be extended. Where would these new commuters park? There is currently limited parking at the station. This would have an impact on local streets and cause displaced parking. Bringing in parking restrictions is not the solution. The town centre is already struggling due to parking restrictions. Where can the town centre workers park? Station facilities would also need to be improved as currently there are no provisions for those with disabilities or those with pushchairs, buggies etc.
The NPPF para 31 says local authorities should work with neighbouring authorities and transport providers for the provision of viable infrastructure. NHDC did not consult with Govia the current train provider, during the preparation of the Local Plan. Govia are themselves conducting a consultation about train services from 2018 onwards and were planning to reduce the peak service trains and are still intending to reduce the off-peak service.
The Plan is not effective as it cannot be delivered in the plan period. It also fails the consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work.
Employment
It will be impossible to create jobs locally for all the new residents in the town. There aren't enough jobs locally currently. There are plans for some industrial space, but the majority of residents will need to commute out of the area. Residents should be able to live sustainably near their place of work, not have to travel great distances. The NPPF para 34 states that 'plans and decisions should ensure developments that generate significant movements are located where the need to travel will be minimised'. Policy SP3 in the Local Plan describes the additional employment provision of 19.6ha of land East of Baldock. It also states that the Council will 'promote and support the expansion of the knowledge based economy in the District. Para 4.23 states that 'many higher skilled residents commute out of the District for employment.'
This Plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. West of Stevenage should be reconsidered. It also fails the criteria 4 ie it is not consistent with national policy as West of Stevenage has not been properly considered.
The NPPF para 28 says that planning policies should support economic growth in rural areas. It should 'promote a strong rural economy' and plans should 'provide the development and diversification of agricultural and other land-based rural businesses.' The proposed site at Blackhorse Farm means building on Grade 2 and 3 active and productive agricultural land. These rural agricultural businesses underpin the rural economy and the character of the landscape. We are encouraged to buy local and buy British, and to encourage UK self-sufficiency. It a strong message that will be undermined by destroying local agricultural land. The proposals will destroy the County Council small holdings on the fringe of Baldock, and will shatter the lives of those who work these areas. They are not just a dot on a map to be erased, they are someone's livelihood and home and it would also be an agricultural loss to the area. Once it has been eroded and developed, it cannot be reclaimed.
Air pollution
In paragraph 9.28, the Plan notes that air quality standards are already close to being exceeded in Whitehorse Street/Hitchin Street. The Housing and Green Belt Background paper notes that former site 209E (Priory Fields in Hitchin) was considered unsuitable for the same reason. Para 124 in the NPPF states that 'Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants.'
This Plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives (ref Priory Fields) and fails the criteria 4 ie it is not consistent with national policy on account of the likelihood of exceeding air quality limits.
Local facilities
Within the proposals there are plans for new schools and health facilities, but these will only be triggered by actual population numbers. So what happens in the meantime to all the new residents while they wait for numbers to reach a threshold? Local services would be unable to cope. We currently have no capacity in our schools and the doctors, hospital and police are all severely stretched. SP14 states that a masterplan must be produced prior to any other detailed matters. No detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added in September 2016) but it does not give detailed plans. Para 177 in the NPPF states that 'it is equally important that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan.'
This is not consistent with national policy as it has not assessed the costs of providing the necessary infrastructure and assumes that costs will be met by developers.
Amenities
We live in one of the most water-stressed areas of the country. The proposed site at Blackhorse Farm would have a huge impact on the local environment. Where would their water be sourced from and where would their sewage be treated? There are already capacity problems at the local sewage works and aquifier. In addition, the area has a known problem of frequent surface water flooding. The NPPF states that Local Plans should take account of flooding risk. This does not appear to be evident in the North Hertfordshire Local Plan.

In the Minister's foreword in the NPPF, he refers to 'sustainable development', 'change for the better', 'positive growth' and 'enhancing and improving where we live'. We need a Local Plan; we need housing for local people. We accept that Baldock will need to grow but the proposed numbers of dwellings are unacceptable. Baldock cannot take this kind of overdevelopment. Residents choose to live in this market town because of its rural character and the way of life it offers. We should protect and preserve its identity.
The proposals in the Proposed Submission Local Plan will irreversibly alter the character of the town, double its population, cause immense traffic flow problems on a heavily-congested road network, further parking problems and add infrastructure problems to our over-subscribed schools and limited healthcare facilities.
In respect of Baldock, The North Hertfordshire Local Plan is not sustainable. Exhaust all the brownfield sites in the area. Be innovative and creative and focus all efforts on a new garden city for the region.

See attachment

I wish to support the contents of this submission in their entirety.
REPRESENTATION TO THE LOCAL PLAN
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. Baldock sits in a valley which is well known for having poor air circulation causing air pollutants like PM2.5 from diesel emissions to be trapped and concentrated. The Eastern Baldock Bypass was finally built in 2003, following intervention in parliament by Sir Oliver Heald MP, to alleviate this pollution.
Since then traffic has risen and now the levels pollutants in Hitchin St and Whitehorse St are in danger of exceeding EU permitted levels (para 9.28). The Housing and Green Belt background paper notes that former site 209E (Priory Fields Hitchin) was considered unsuitable for exactly this reason.
The extra vehicles, domestic and service vehicles, which will arise from the building of 3,590 new homes and which will travel through and around Baldock will tip the balance and affect the health of all residents especially the very young, the old, pedestrians and cyclists raising health problems such as respiratory disease, cardiac problems and even cancer.
The Plan is UNJUSTIFIED as it is not the most appropriate strategy.
4. The local highways network will be severely affected by the development of this site. Almost all of the traffic wishing to pass through Baldock travels from the A1 to Buntingford and Stanstead along the A507, and from Cambridge and Royston towards London along the A505 (now redesignated B656), and these two roads cross at traffic lights at the north of Baldock at Station Road and Whitehorse Street. The two roads are offset and the traffic lights are slow because of three way lights and now pedestrian crossing time when requested, mainly at school rush hours. The crossroad is bounded by listed buildings which makes turning difficult
especially for the huge lorries on the A507, some going left to Royston at that junction, which still go that way despite recommendations that they use the A1 and new bypass. One of the listed buildings has suffered many hits by vehicles.
The proposed mini-roundabout at Whitehorse St / Station Rd crossroads, the only mitigation planned for Baldock (AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction.
The A507 passes the only access 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 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. I can report, as a resident of this road, that the traffic volume has increased substantially since the Bypass was opened in 2003 and particularly since the A1 services at Radwell were built. GPS navigation also directs traffic along this road as an alternative to the A1/ Eastern bypass.
All of this ensures that the A507 from the traffic lights to the A1 roundabout is not a suitable road to give access to a new development at BA1 as NHDC plans. It is very likely, since there are few work opportunities in Baldock that most of the residents will commute to other parts of North Herts, Bedfordshire and Cambridgeshire.
NHDC has projected 2-3 vehicles per house so 5-7000 vehicles 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.
5. Baldock's railway station is on the northern edge of the town with few houses lying to the north of the railway line. A major development on this side of the railway line would result in a pinch-point for traffic at the Whitehorse St/ Station Road intersection. The AECOM's technical note, table 4.1, identifies this crossroad and Letchworth Gate at the southern end of Baldock as problems (above capacity, unacceptable queuing) by 2013 even without further development.
The Plan acknowledges that "not all" traffic from BA1 will have to use the Whitehorse St/Station Rd crossroads (4.179) but this also acknowledges that a good proportion of it will. The Plan makes employment provision at above modelled levels SP3, 4.26 and this could increase traffic flow between Baldock and Letchworth and Hitchin. The plan stresses how interconnected Baldock Letchworth and Hitchin are (paras 2.31, 4.27, 13.14) and that many residents commute out (4.25, 4.26). This will lead to more peak hour traffic.
Since it is expected that most new Baldock residents will commute to work outside Baldock, as well as extra pressure on the roads there will be unacceptable pressure on the railway. The station is small and would need extending to accommodate more passengers and the longer trains needed for them. 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.
6. The National Planning Policy Framework states in para 32 that "All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. Plans and decisions should take account of whether" "the opportunities for sustainable transport modes have been taken up but the Plan does not give information of things such as cycleways between towns for commuters, "safe and suitable access can be achieved for all people" but the increased traffic on A507 and through any link road and under the very narrow railway bridge will act against this, "improvements can be taken within the transport network that cost
effectively limit the significant impacts of the development. Development should only be prevented or refused where THE RESIDUAL CUMULATIVE IMPACTS OF DEVELOPMENT ARE SEVERE".
The full impact of the scale of development proposed for Baldock - 3590 homes BA 1/2/3/4 and BA10, industrial development or the individual major sites,- have not been properly assessed. Nor has evidence been offered on the impact of these developments on the existing town of Baldock and its environs and its local transport network. No information has been given about proposed mitigation measures.
The Plan is NOT CONSISTENT WITH NATIONAL POLICY.
7. The Plan does not retain and enhance the town centre of Baldock as recommended by the NPPF (para 23). Indeed by trying to build a new development BA1 on the other side of the railway line it encourages a 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. The protection of the Ivel Nature reserve has been glossed over as has the mitigation measures for protection of other wildlife such as the endangered corn bunting on BA1.
It is important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion" NPPF 177. The Council have failed to provide detailed plans, timescales or costings for the necessary infrastructure and this gives no confidence that said infrastructure will be provided at the times it is needed, of a good quality, or even at all. Other developments in the area eg Great Ashby have discovered this to their cost.
The Plan is neither JUSTIFIED nor EFFECTIVE nor CONSISTENT WITH NATIONAL POLICY.

NHDC Proposed Local Plan October 2016
This letter sets out a number of objections to the proposed Local Plan dated October 2016 by NHDC based on two of the "Tests of Soundness" set out in the National Planning Policy Framework ("NPPF"), namely a Local Plan should be:
"Effective - the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities; and
Consistent with national policy - the plan should enable the delivery of
sustainable development in accordance with the policies in the
Framework."
The proposed Local Plan falls short in a number of areas, in particular:
the viability and vitality of Baldock;
inadequate plan for transport infrastructure in the North Herts area generally;
inadequate plan for transport infrastructure as a result of the proposed developments in Baldock, in particular BA1, BA2 and BA3;
inadequate plan for the development of core infrastructure such as schools, doctor surgeries, leisure facilities; and
impact on Green Belt
There is clearly a need to increase the housing capacity to allow for the expanding population and the increasing employment opportunities in London and surrounding areas. All areas must contribute to the expansion, however the proposals in the Local Plan are not workable and lack a holistic approach to transport and core infrastructure and will destroy the essence of the historic market town of Baldock.
The letter sets out in more detail the details of the objections and then discusses alternate ways and amendments that could achieve the objectives.
Viability and vitality of Baldock
Baldock is an historic market town with a vibrant community spirit. The centre of the town is characterised by a wide high street, numerous public houses and restaurants, specialised retail outlets including an award winning butchers. There are a number of events throughout the year that bring together the local community, in particular the Baldock festival in May, a free music festival in September, the charter fair in October, numerous farmers markets and other cultural events in the recently refurbished Town Hall and market square.
All of these events allow the people of Baldock to come together as a community and build friendships. The housing in Baldock itself is generally quite modest and therefore the people are of broadly like minds. Over the last 30 years there has been an expansion of housing, primarily on Clothall Common, but in smaller developments of up to 20 houses. This type of expansion enhances the community spirit in Baldock, however the town amenities are at capacity and the proposed increase of 80% more homes threatens to destroy the community spirit and overburden the amenities in the town centre which has limited capacity to expand.
The recreation facilities in the town are limited today. The Town Hall is recently refurbished and is operated by volunteers primarily for art and musical activities. The Community Centre has three function rooms which are used a variety of clubs for all ages. Both have limited capacity and are just about sufficient for the needs of the town, the proposed expansion would render them inadequate. There is a bowls and cricket club located on Avenue Park, which are popular, and Baldock Crusaders netball team use the public courts also at Avenue Park. These facilities are functional but have limited capacity. There is a junior football club (Baldock Town Youth FC) which uses pitches at Hartsfield School and Knights Templar School, the proposed increase in population would mean that more football pitches would need to be made available, preferably with a club house. There is no mention of provision of any additional recreational facilities in the proposed Local Plan.
Baldock has excellent schools, three primary and a secondary school (Knights Templar School). All work together well and receive good or outstanding reports from Ofsted and they are very much part of the community. All of the schools are at full capacity with limited (at best) room for expansion in buildings and facilities, and even less capacity financially, as recently highlighted by an appeal from Knights Templar to parents to help buy
equipment for a newly built science block. The proposed Local Plan sets out a policy for expanding capacity by 8FE, however there are no details on the location or timing of the building of this extra capacity. A condition of any permission must be the building of sufficient school capacity in advance of any housing expansion and that the new schools must be associated with the existing school structures.
The proposed Local Plan has failed to take into account adequately the unique community spirit, recreation facilities and schooling requirements and therefore fails the Test of Soundness to be consistent with national policy, in particular:
NPPF paragraph 70 requires a Local Plan to plan positively to deliver the social, recreational and cultural facilities and services the community needs - the lack of any provision in the proposed Local Plan for Baldock in BA1, BA2 and BA3 demonstrates this has not been done
NPPF paragraph 72 requires sufficient school places are available, the proposed Local Plan for Baldock in BA1, BA2 and BA3 lacks any detail on how and when this will be delivered.
NPPF paragraph 74 requires a Local Plan to provide access to high quality open spaces and opportunities for sport and recreation, in the proposed Local Plan for Baldock there is no acknowledgement of the limited capacity of current amenities or the need to create expanded facilities.
Transport in North Herts
The area between Hitchin, Letchworth and Baldock is already over capacity for the infrastructure that serves it. The employment level in the area is high but with limited jobs available in the immediate area, a significant amount of the people commute to work either by train or by car using transport links that are already at capacity, specifically:
peak time trains into and out of London are always crowded with inadequate seating and regular delays;
the train operating company has recently announced plans to change the service into London, it was reported at recent meeting that the councillor who prepared the plan was unaware of the changes and the adverse impact they would cause, in particular on off peak journey times and overall capacity;
the A1(M) has solid queues every day between 6.30 am and 9.15am from Junction 10 (Baldock Services) to Junction 6 (Welwyn Garden City) caused by only having 2 lanes for the majority of the distance and increase in usage over the last 10 years with the expansion in towns such as Biggleswade, Stotfold, Stevenage and Shefford;
in the evening peak between 4.30pm and 7.00pm there is a solid queue between Junction 5 and Junction 8
the main through road from Baldock to Hitchin (the B656) has queues into and out of Hitchin and Baldock because of the sheer weight of traffic
there is a significant pinch point at Junction 9 coming out of Letchworth, which causes drivers wishing to travel to Royston, Baldock and Buntingford to avoid this and go through Baldock town centre
As a result journey times are at least double what they should be with significant overcrowding on trains. The proposed expansion in housing proposed in the Local Plan will obviously increase significantly the demand on these key transport links, however it does not make any mention of proposals to alleviate the problem, therefore it is not consistent with national policy in a number of areas:
NPPF Paragraph 34 sets out "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised". With limited employment opportunities in the North Herts area the proposed developments have not considered minimising the need to travel.
NPPF Paragraph 36 requires that where there is a significant amount of movement a Travel Plan is published with the Local Plan. The expansion of Baldock by 80% qualifies as "significant amount of movement" and no Travel Plan has been produced.
Transport in Baldock
Baldock is an historic market town of approximately 4500 houses. The proposed Local Plan is seeking to increase the size of the town by 80%. The transport infrastructure does not cope with current demands and therefore an increase of 80% without significant infrastructure development will grind the town to a stop and the consequential impact on the town centre and
environment will increase public health issues and reduce the enjoyment of living in Baldock with its vibrant community spirit.
 The road system in Baldock has been shaped over hundreds of years and has a pinch point at an intersection of the A507 and B656, which is managed by traffic lights and the junction itself is surrounded by listed buildings which prevent any material changes to the junction.
 Traffic at peak times in the morning and evening mean queues onto the junction are regularly in excess of 10 minutes from all directions with the exception of cars coming from Royston.
The railway station is located near to the intersection, it has limited parking, and is accessed from the A507 approached from the North. As has been stated, there are always queues into the intersection and so getting access to the station by car takes significantly more time than necessary.
Approaching from the north of the town along the A507 there is a railway bridge which has very little space for pedestrians and cyclists to access alongside the queuing traffic. This particularly is dangerous, and with the proposed building of 2800 houses in site BA1 the situation will become critical and lives will be endangered. The proposed Local Plan does not have any policy to alleviate this issue.
The capacity of Baldock station is limited, there is not adequate covered area on the platform, parking spaces are limited but adequate, the ticket office is open for a limited time in the morning, there are no retail facilities or toilets, and the train operating company is proposing to change the off peak service times. It is a small station. It is fair to assume a large majority of the people who would move into the new houses will commute to London and therefore the station facilities must be upgraded as part of any proposed expansion in the town.
 Following the recent town centre development, parking in Baldock is limited but adequate for the demand today, and any material expansion in population will cause parking problems and there are no proposals to alleviate this.
The proposed southern link road associated with BA2 and BA3 has no details. Whilst it may alleviate some pressure on the intersection of the A507 and B656, it could create a route through the Clothall Common estate which will increase the safety of the residents who benefit from the estate being a no through road. Any proposed development should
simply create a junction between the A507 and the new A505 Baldock bypass.
In the proposed BA1 development, there is a proposal to create a link road from the A507 between Junction 10 of the A1(M) and the roundabout east of Baldock on the A505. This road will be extremely busy, it must be a dual carriageway and it must be built in a cutting with adequate provisions for noise and air pollution reduction. The proposed Local Plan does not provide any details of the nature of this road
Any one of these points on their own are enough to demonstrate the proposed Local Plan does not take into account the transport needs created by an expansion, but in aggregate they demonstrate the proposed Local Plan is unworkable and therefore fails the Test of Soundness on the grounds of not being Effective and inconsistent with national policy, in particular:
 NPPF paragraph 31 requires neighbouring authorities to be included in the development of strategic solutions for viable infrastructure, this clearly has not happened with the train company, Network Rail or the authority responsible for highways.
NPPF paragraph 35 requires the Local Plan should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. The lack of any proposals in BA1, BA2 or BA3 for improving pedestrian and cycling links, in particular through the railway bridge on the A507 demonstrates no consideration has been taken to encourage sustainable transport for Baldock.
NPPF paragraph 39 and 40 set out policies to ensure there is adequate parking in town centres. There are no proposals in BA1, BA2 or BA3 to address the increase in demand for the parking in Baldock town centre.
Core infrastructure in Baldock
Baldock has one doctors surgery which provides an excellent service but it is notoriously difficult to get an appointment. Parking at the surgery has been removed and there is no physical capacity to expand the practice. The proposed Local Plan for Baldock makes no proposals on the addition of additional GP capacity.
The nearest hospital is Lister in Stevenage. There has been considerable investment in the capacity and services at the hospital but it is still operating at capacity and the proposed increase in housing will place additional burden an already creaking system. There is no discussion on increasing the capacity of the hospital.
Baldock has two care homes for the elderly. The ageing population and increasing demands for social care mean that the existing social care provision will be inadequate for an expanded population. The proposed Local Plan makes no reference to how social services will be expanded to cope with demand of the residents as well as the increasing demands of the existing population.
I have already set out the position that the proposals in the Local Plan contain inadequate details about the provision of additional schooling, but this is another example of the lack of coordinated planning in the proposal.
Taken in aggregate the lack of provision in the proposed Local Plan for the Baldock area fails the Test of Soundness to be Effective and to be consistent with national policy, in particular:
The proposed Local Plan does not consider the broader infrastructure required to service the expanded the Baldock community;
NPPF paragraph 17 set out 12 Core Planning Principles that should underpin plan-making and decision-making, the proposed Local Plan does not apply the following:
o #3 - proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs;
o #4 - take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it;
o #11 - actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable; and
o #12 - take account of and support local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs.
Impact on Green Belt
Four of the large "strategic developments" proposed by NHDC, including the Blackhorse Farm development, have been located on Green Belt land. Paragraph 80 of the National Planning Policy Framework lists five purposes for the Green Belt:
1. to check the unrestricted sprawl of large built-up areas;
2. to prevent neighbouring towns merging into one another;
3. to assist in safeguarding the countryside from encroachment;
4. to preserve the setting and special character of historic towns; and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
Table 5 in the North Hertfordshire Green Belt Review6 provides a "Green Belt Review Assessment Matrix". The Green Belt has been divided into sectors, and each sector is subjectively assessed against the first four of the five Green Belt criteria listed above. However, the table does not provide any assessment in relation to the fifth criterion, which demonstrates there is no evidence of urban regeneration in this Local Plan.
The proposal in BA1 north of Baldock is clearly urban sprawl, and is exactly the kind of development the Green Belt was intended to prevent. How has this been allowed to happen when the scale of the site is so out of proportion with the size of Baldock? Through research it is clear that the site has been chosen out of political expediency as the land is owned by Hertfordshire County Council and by allocating such a large scale development without due consideration of the impact on the town of Baldock, as demonstrated in this letter, was the path of least resistance, ignoring the NPPF and best practice for planning.
NPPF paragraph 87 and 88 sets out that inappropriate development harmful to Green Belt will not be approved unless there are "very special circumstances". The proposed Local Plan does not make it clear what the very special
circumstances are that mean the significant development proposed in BA1 should be approved.
Alternative Approach
Having demonstrated the proposed Local Plan does not pass Tests of Soundness across a number of elements and therefore does not constitute a sustainable development, there is still the underlying need to increase the housing capacity. I believe a more strategic and holistic approach is needed, not just in North Herts but with associated districts, and such an approach needs to address the following points before any significant housing developments are started:
Increase the capacity of the A1(M) from Biggleswade to Welwyn to have at least 3 lane, but preferably 4 lane carriageways;
Build a bypass for the whole of the Hitchin, Letchworth and Baldock to alleviate the pressure on the B656 (old A505 route) and the associated pinch points such as the intersection between the A507 and the B6565 in Baldock. Wherever possible this bypass will be built in a cutting and be dual carriageway;
Identify a site where a new town, built on Garden City principles, for up to 10,000 houses and associated infrastructure can be built with close transport links to rail and road - the site West of Stevenage is ideal and a tram route can be built to transport commuters to Stevenage station;
Identify the site for a new hospital or significantly expand the capacity at Lister Hospital;
The plans for building on site BA1 should be shelved in favour of the consolidated larger new town;
To accommodate a small increase in housing in BA2 and BA3 in Baldock, there should be a new intersection built on the intersection of the A507 and A505 new Baldock bypass and an expansion of capacity in local schools, community amenities and social care provisions
Summary
The proposed Local Plan does not support the principle of sustainable development and fails Tests of Soundness on a number of levels. There is no fully costed plan because all of the elements such as transport and schooling have no details to be able to fully cost them. The approach seems to be build the housing then worry about the infrastructure later, this is totally flawed and
will destroy the viability and vitality local Baldock community. Finally, the sheer scale of the proposed expansion is out of all proportion and would in and of itself ruin the beautiful town of Baldock.

We wish to protest about the utterly unfair, disproportionate and unjust proposed housing developments at Baldock which will ruin our lovely town. Ever since NHDC was formed Baldock, as its smallest town, has been at the back of the queue for everything and now the Council has decided to dump the bulk of its housing allocation on us simply because it is easy to do so and because we do not have the power or the votes to prevent it. It is a mockery of democracy and so-called localism.
Baldock has already undergone enormous expansion in the last 60 years or so and
particularly in the last 35 years. It is remarkable that it has managed to keep some of its rural charm, historic character and sense of community through all those changes and the indifference of successive Councils. It is unlikely to survive the sheer scale and rapidity of these latest proposals and a unique community will be lost forever.
Natural Environment, Historic Environment, Countryside and Green Belt:
* The Ivel
These four large developments are bound to have an adverse effect on the water table, threatening not only our water supply but also the rare chalk stream habitat of the River Ivel which rises on the northern edge of the town and draws its water from the same chalk strata. The Ivel already suffers from the growth of the town as it is now and the effects of an increase of a further 75% of housing could cause severe damage.
The Plan does not seem to have made any assessment of the likely damage to the water supply or the river nor does it include any plan to avoid these effects.
* Sewerage
The Plan does not say whether or not it has been ascertained if the sewerage pumping station at Baldock (all Baldock's sewerage flows into the Ivel after treatment) can cope with a 75% increase in sewerage and prevent an overflow into the Ivel.
* Green Belt
The Plan involves building on Green Belt contrary to Government guidelines when there is a preponderance of non-Green Belt land in the District.
* Heritage:
No account been taken of the historic landscape setting of the town contrary to
Government guidelines specifying 'that heritage assets are an irreplaceable resource'
and should be conserved 'in a manner appropriate to their significance'.
The Plan quotes the NPPF guidelines as saying that there should be 'conservation and enhancement of the natural and historic environments, including landscapes' yet it treats the historic environment as a separate matter relating only to conservation areas and listed buildings. A town or village is often an important part of a landscape and it is ridiculous to treat them separately.
The Plan claims to refuse developments (NE1) that are 'have a detrimental impact on the appearance of their immediate surroundings and the lanscape character of the area' without 'suitable mitigation' yet have not even considered the matter in regard to the proposed spoliation of some fine landscapes, particularly the very attractive valley and landscape views leading down to the town from the hills around Clothall and Quickswood which will be badly spoilt by BA2 & BA3. BA1 will also spoil an attractive piece of countryside on Bygrave Common which is an important part of the setting of the Ivel Springs Nature Reserve and of the town itself.
Infrastructure Delivery:
* Roads:
Baldock's road system in the historic town centre is already badly congested at certain times of the day with consequent severe pollution in Whitehorse Street and Hitchin Street where, according to |NHDC, levels of NO2 are 'close to exceeding National Air Quality objectives'. This is despite two major bypasses carrying non-local traffic.
Most of the traffic through and in the town is local traffic which appears to be going
between Baldock and Letchworth (the industrial estate of the latter being the main local source of local employment). This congestion is severely aggravated at the times of the school run. The main traffic queues occur in Hitchin Street, Station Road/North Road and Clothall Road because of the junctions at either end of Whitehorse Street (only about 250 yards apart) which street carries the greatest volume of traffic. The proposals for all four sites will add to this problem by adding local traffic in significant volumes yet the Plan claims that it 'addresses the protection of the health of residents'.
The great size of the BA1 scheme would greatly increase the problems in North
Road/Station Road, Whitehorse Street and Hitchin Street for the above reasons. The
railway line blocks any convenient alternative. The proposal to run a relief road to the eastern Baldock exit on the southern bypass is impractical because it is incovenient for most local traffic flows (ie. to Letchworth, where it would meet queues at Letchworth Gate,) and would mean a long detour to most local destinations to the west. It would also be very expensive. One might also add that if two major bypasses have not prevented traffic problems in Baldock this proposed relief road running in the wrong direction is unlikely to succeed.
The plan does not include any idea of the cost that the railway may impose for allowing a bridge to be built for the relief road, or the cost of the bridge, or who would be liable for the cost.
BA2, BA3 and BA4 would also cause further congestion at the Whitehorse Street
junctions and would cause increased traffic along South Road, a residential street not well adapted, or adaptable, to high traffic flows and already suffering as a 'rat-run'.
There is no obvious, viable means of alleviating these problems.
* The Railway:
The railway is already at capacity how will it cope with this number of extra commuters?
It is even proposed that the number of trains is to be cut which will make the situation
intolerable because many of the likely new residents will be commuting by train.
Logically large scale housing would be better sited near to the main line railway, not
this branch line, and near to the three lane section of the A1.
* Pedestrian access:
Pedestrian access to the town from BA1 is poor because of the narrow pavements under the railway bridge and the consequent risk to pedestrians and especially children, this will only add to the traffic problems as people would use cars for school runs etc. instead of walking.
* Services
The scale and speed of these changes will mean that the schools, medical services, the doctor's surgery will be unable to cope. Where is the money going to come from to pay for all this? Where will the extra doctors and nurses come from?
Conclusion There seems to be no attempt in the Plan to find any alternative to this inequitable and disproportionate distribution of housing. No real attempt has been made to encourage other landowners to come forward with possible sites, not even the County Council which holds many other parcels of land in the District. Why, for instance, have the large HCC holdings north of Ickleford not been considered? They are conveniently placed for the mainline railway at Arlesey and for major employment centres at Hitchin, Bedford and Letchworth.
Like so many plans of this sort this Plan contains many fine sounding aspirations and
policies which are simply ignored when it does not suit and is therefore so much highflown verbiage. This cannot disguise the failure to follow the NPPF guidelines in many instances, or the basic dishonesty and unfairness of these proposals which threaten the future of this town, its sense of community and its quality of life as well as the natural environment.

I would like to protest most strongly, on behalf of the members of this Society, about the possibility of massive and disproportionate housing development at Baldock. The following remarks refer to site references BA1, BA2, BA3 and BA4.
1. Historic Environment (HE) & Countryside and Green Belt (CGB):
As a History society the first matter we wish to draw your attention to is the effect any large increase in housing would have on the historic character and culture of Baldock and its setting within the countryside. This historic value of the town has been noted over the years by various authorities and I summarise them below for your information:
* Sir Patrick Abercrombie's Greater London Plan of 1944 considered Baldock to be
compactly developed with little discordant building and with a pleasing
relationship with the countryside, especially towards the north. In other words an
unspoilt, small country town. The report concluded that the town was "not
topographically suited for any appreciable expansion".
* In 1974 the Department of the Environment assessed the Baldock Conservation
Area as being of Outstanding Historic Interest.
* In 1977 NHDC and HCC jointly published the Baldock Town Scheme which
stated that "Baldock is one of five Hertfordshire towns listed by the Council for
British Archaeology as being of National Importance".
* Today the town has over 100 listed buildings in the town centre, equivalent, pro
rata, to an historic centre like Ely. It has one of the finest medieval churches in
Hertfordshire and the relationship of the church with the town clustered around in
its attractive valley setting is an important part of its charm.
Over the years neither BUDC nor NHDC have taken notice of these views or taken much care of the historic townscape and the rural setting which is so vital to it. The town has doubled in population since 1945 but nevertheless has managed to retain some of its rural charm and small-town feel because to the north and north-east there has been little development and because the countryside still reaches into the town from the south-east.
Yet these are precisely the areas that the Council have listed for development.
The Council planners appear to have completely ignored the requirement of the National Planning Policy Framework which requires that councils must "recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance."
Likewise they have ignored the Government's intention that the Green Belt (which, like all the countryside, must surely also be considered a 'heritage asset') should be
preserved. Instead the only discernable planning issue that appears to have been taken into account is availability and political expediency, that is to say, 'let us dump these houses on the smallest town with the smallest vote'. As Sir Oliver Heald, MP, has pointed out, Green Belt land is supposed to be protected wherever possible yet, even though most of the District is not Green Belt, the Council have allocated the bulk of the housing on Green Belt land.
It seems from their Local Plan documents that the Council considers that its
responsibility for the heritage aspect of the towns in its care extends only as far as the boundaries of their conservation areas (this is despite the requirement of the NPPF that there should be 'conservation and enhancement of the natural and historic environment including landscapes' clearly implying that the two are one and the same, and that the setting of one in the other is important.) The Council's Plan is indifferent to this and the likely consequence, as far as Baldock is concerned, can be seen elsewhere all over the country in, what English Heritage calls, 'heritage ghettos': isolated islands of old buildings along a street frontage surrounded by unsympathetic and inappropriate urban development and infilling. Baldock's heritage character is that of a small country town in its country setting and that is the 'heritage asset' that should be preserved and not simply a selection of old buildings.
2. The economic effect on the town (ETC):
To a great extent, the economy of Baldock town centre, such as it is, relies on its
attractive character to draw people into the town. However, if there is to be any
significant return to a prosperous town centre it will need to attract more tourists and visitors from outside the town because the experience of the last 30 years has
demonstrated that population growth does not bring noticeable extra trade to the town centre. The town has only one real asset to attract that further trade and that is its historic character, because it has little else to offer a visitor. Without that asset there is little hope of a recovery. The Plan says that the survival of tourism "depends upon conserving and maintaining the quality of the resources upon which it depends" (ETC5) yet in Baldock the housing proposals threaten to destroy that very quality of attractiveness that is its only relistic hope.
In fact there are signs of prosperity returning to the town centre for the first time in
decades and visitors are being attracted to the town because of its character. The recent improvements to the town centre seem to have played a part in this and, with the new Arts and Heritage Centre project, there are grounds for hope that things may improve further, but it is a tenuous hope and could easily be destroyed by massive, unsympathetic development.
I should also point out that these considerations do not apply, to anything like the same degree, to the other towns in the district which are already of such a size that a few thousand extra houses would make little difference to them. The proposals are more akin to hugely increasing in size an historic village like Ashwell. It will be noted that Council would not countenance such an increase at Ashwell and yet almost precisely the same arguments apply to Baldock as they do to Ashwell.
Natural environment (NE):
Apart from the aesthetic damage to the landscape these proposals will bring and the loss of valuable farmland (which ought to be considered vital for our food security) we are concerned about the potential damage to the River Ivel. It is noticeable that the Ivel, which is an important and rare chalk-stream habitat, as well as an important local amenity, has run dry on several occasions in recent years and there is the possibility of doing irreversible damage to the river, its flora and fauna and environment, if the local water table or the capacity of the sewerage treatment works is overwhelmed by such a large increase of housing. This is not a concern that is really dealt with in the Plan except in vague terms.
There is also the related question as to whether local ground water sources can adequately supply the river and a development of this size with water especially in time of drought.
A great deal of money was spent on carefully landscaping the A505 Bypass to minimise its environmental impact on the lower end of what is surely one of the prettiest valleys in the District with its picturesque views of the town from the hills at its head. This would be so much money - ratepayers' money - wasted if the 'trapped land' is to be developed in BA2, and BA3.
Infrastructure delivery (ID):
Baldock's road network is already under strain despite having two bypasses. For large parts of the day there is congestion in the historic town centre which cannot be relieved because it is caused largely by local traffic. The Council acknowledges that this already causes significant pollution in the Whitehorse Street and Hitchin Street areas which nearly exceeds national guidelines and yet despite claiming that your policy 'addresses the protection of the health of the residents' it will, in fact, make it worse.. A massive increase in housing would exacerbate these problems and, because so much of the traffic is local with local destinations, they are unlikely to be solved by the proposed relief road to the eastern A505 junction in area BA1. If the present town is still congested after the construction of two bypasses then a town 40% larger is not going to be relieved by a third bypass heading in the wrong direction. Wrong, that is, because most of the traffic through the town centre seems to be going to or from Letchworth with school runs also causing extra difficulties at certain times of the day. No one would use this proposed relief road to go to Letchworth, or the supermarkets, or the schools, because of the length of the
diversion and the likelihood of traffic jams on Letchworth Gate.
Area BA1 is a particular cause of concern here because its sheer scale is likely to cause severe congestion at the Whitehorse Street/Clothall Road/Station Road/Royston Road junction which will also have to cope with added traffic from BA2, BA3 and BA4.
Pedestrian access to the town from BA1 would also be severely limited by the
dangerously narrow pavements under the railway bridge and it is hard to imagine that parents would be happy for younger children to use it. This would add to the likelihood of BA1 being cut off from the town and increasing congestion on the school run.
The proposals for BA2, BA3 and BA4, as well as increasing traffic volume at the
abovesaid junction would mostly add to the existing problems in South Road, a
residential road that is already being used as a 'rat run' and is too narrow to deal with greater volumes of traffic The Preferred Options Plan appears not to have investigated the feasibility of the third bypass/relief road for BA1, either as a realistic means of relieving the congestion in the town centre or for its economic viability. In effect the railway holds a ransom strip and may use it to extract a sizeable sum. There is also the cost of building a bridge over the railway. Who would pay these costs? Is it the developer or the Council? If the latter why
should we be throwing ratepayers money at, what the NHDC's own planning portfolio
holder considers, a 'flawed plan'?
The proposed increase is proportionately so large and so rapid that it is going to put
severe strain on schools, medical services, surgeries, water supply and the railway system none of which are likely to be adequately catered for and some of which are beyond the control of the Council but nevertheless need to be considered. It will therefore cause significant problems and severely impact on the quality of life of the residents of this town and neighbouring villages.
As Baldock's treated sewerage flows into the Ivel it is vital that the treatment system is able to cope with a 75% increase in volume and be in place before a problem occurs. Has the cost of this been assessed and, again, who is to pay for the consequent costs?
NHDC's Vision and Objectives for Baldock:
It would seem that there is no discernable vision or viable plan for the future of Baldock beyond dumping the bulk of the District's housing problem here. There is no indication that there will ever be an ultimate capping of population/housing or any alternative to further urban sprawl, just a rush to solve an immediate problem.
There seems to have been no attempt to find alternative sites for housing in order to
spread the distribution more fairly. In particular there is no indication that Herts County Council has been approached about any of its other considerable landholdings within the District. There is a sizeable holding north of Ickleford, for example, on a very unremarkable, flat piece of countryside (unlike the attractive countryside around Baldock); it is convenient to Arlesey Station on the mainline which would be far better able to cope with increased traffic than the Cambridge branch line and it is on the main Hitchin to Bedford road with consequent employment opportunities in those towns, yet it has not been considered.
Baldock, on the other hand, has few employment opportunities, except those offered on the Letchworth Industrial Area, and this fact will be another cause of increased traffic through the town.
The consequence of dumping far more houses than the town needs, or that local
employers require, is that Baldock will become largely a dormitory town with a
consequent detrimental effect on its sense of community and its economy.
All three of our MPs consider the plan flawed, inadequate and unfair; even the NHDC
Planning Portfolio holder apparently agrees. If so, how can it be acceptable to proceed with a flawed plan?
Most people would surely agree that to meet the District's quota each town and village should accommodate its own housing needs and those of the employers and industries within those communities. It is against all natural justice and fairness that the quota should be allocated largely to one town simply because the land has been made available and because it is the smallest town with the least votes and power to oppose it.
This Local Plan threatens to destroy the identity of the last remaining small rural market town in your District and the equally precious sense of community that makes it such a pleasant place to live.

See attached

Having considered the draft Local Plan, we do understand the need for future housing development to accommodate the ever expanding and growing population. However, we struggle to comprehend the inequitable allocation of 2,800 homes proposed for the Land North of Baldock referenced BA1 in the proposed Local Plan. We feel it will have a detrimental impact on the historic market town of Baldock itself, effectively creating a separate environment which will be in direct competition with Baldock itself. Not withstanding the massive disruption to the local community with increased traffic building machinery etc required for the build process itself. This will also put increased pressure on Junction 10 of the A1M which currently struggles during peak times of the day.

As the proposed site is a green field site, which normally is not permitted for development, many local small holdings will lose their land and their livelihoods, as well as the loss of a huge area of countryside which itself supports wildlife.

We can see Policy SP14 appears to make reference to the need to integrate the "new scheme" as well as possible by proposing extensive planting schemes, as well as a new link road connecting the A507 to the A505. All of which will be very costly indeed.

Although we do sympathise with the challenges of satisfying future housing requirements we are unanimous in our decision not to be able to support the proposed new Local Plan until we are confident or advised further as to how the proposed new development schemes will be financed.

See attachment