Policy SP14: Site BA1 - North of Baldock

RE EXPANSION PROPOSALS TO BALDOCK AND BYGRAVE

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 wish to object to the Local Plan as the proposal to build 3,290 new homes in Baldock by 2031 is unjustified, not effective not sustainable and is inconsistent with National Policy.
Quite simply, the local plan is proposing to build too many houses in the wrong places. Rather than distributing the numbers equitably across the locality and making full use of available brownfield sites, there appears to be have been a desire to provide a 'quick fix' regardless of policy and the consequences, by building a large proportion of these houses on Hertfordshire County Council owned green belt land.
This approach is unjustified, not effective, not sustainable and not in the interests of the Historic town of Baldock, its residents, the surrounding community nor the resident wildlife, much of which has protected status.
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, stress 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 they both deliver traffic. Station Road passes under the 14ft 6in railway bridge which historically has suffered frequent hits by lorries (8 or so per year). Despite the building of sacrificial metal beams at each side of the bridge and new signage the hits continue to occur. Whilst the long delay to rail traffic no longer happens, road traffic is still impacted while the mess is cleared up, the vehicle is extracted, two police vehicles are deployed. In addition to this there are numerous smaller holdups when lorries realise they will hit the bridge and manoeuvre via small residential roads damaging road furniture and grass verges as they do.
The traffic on the A507 is constant and heavy especially in peak periods which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case. In the IDP the Traffic Baseline (para) shows that for North Herts as a whole traffic volume between 2014 - 31 is expected to increase by 16.1% and the average commuting distance in 2011 was 19.4km. Rail patronage at Baldock (para 5.12) went up 61% between 2005/6 to 2014/15. Para 5.19 mentions cycle paths in North Herts including Baldock but those referred to are mainly for leisure. Traffic demand in the A1 corridor may increase by 30% by 2031. No traffic surveys on the A507 have been carried out by NHDC for development of this Local Plan. It has not been included in any meaningful traffic modelling exercises during research and forward planning. 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. [Type text] 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 foreward 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.
Where will these new residents work and how will the land designated for industrial development be used? There are few new work opportunities here so most will commute out of Baldock. This will have a massive impact on roads and railways which are already overburdened and close to breaking point. Should areas closer to centres of employment such as West of Stevenage not be considered.
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 pinchpoint for traffic and a pulling apart of the community. Developments should "be expected to work closely with those directly affected by the proposals to evolve designs that take account the views of the community (NPPF 66) but NHDC have not done this. They have not sought the views of existing residents. "By designating Local Green Space local communities will be able to rule out new development other than in very special circumstances". But NHDC have decided to locate many sites including BA1 on Green Belt land going in the face of this policy. They have not provided appropriate justification for redesignating Green Belt land as they should, showing "exceptional circumstances". Indeed the area BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as shown in NPPF chapter 9. It is good quality agricultural land and of great importance for feeding the local area. "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use poorer areas of land in preference to that of a higher quality NPPF 112.
The impact on local wildlife has also been ignored. Many rare species of birds including corn buntings breed and are resident in this area. Corn buntings are protected in the UK under the Wildlife and Countryside Act, 1981, classified in the UK as a Red List species under the Birds of Conservation Concern review and as a Priority Species in the UK Biodiversity Action Plan.
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.
I should like to be kept updated on the Plan's progress I should like to be invited to the Public Hearing.

REPRESENTATION TO THE LOCAL PLAN

I wish to object to the Local Plan as the proposal to build 3,290 new homes in Baldock by 2031 is unjustified, not effective not sustainable and is inconsistent with National Policy.
Quite simply, the local plan is proposing to build too many houses in the wrong places. Rather than distributing the numbers equitably across the locality and making full use of available brownfield sites, there appears to be have been a desire to provide a 'quick fix' regardless of policy and the consequences, by building a large proportion of these houses on Hertfordshire County Council owned green belt land.
This approach is unjustified, not effective, not sustainable and not in the interests of the Historic town of Baldock, its residents, the surrounding community nor the resident wildlife, much of which has protected status.
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 signicficant 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, stress 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 they both deliver traffic. Station Road passes under the 14ft 6in railway bridge which historically has suffered frequent hits by lorries (8 or so per year). Despite the building of sacrificial metal beams at each side of the bridge and new signage the hits continue to occur. Whilst the long delay to rail traffic no longer happens, road traffic is still impacted while the mess is cleared up, the vehicle is extracted, two police vehicles are deployed. In addition to this there are numerous smaller holdups when lorries realise they will hit the bridge and manoeuvre via small residential roads damaging road furniture and grass verges as they do.
The traffic on the A507 is constant and heavy especially in peak periods which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case. In the IDP the Traffic Baseline (para) shows that for North Herts as a whole traffic volume between 2014 - 31 is expected to increase by 16.1% and the average commuting distance in 2011 was 19.4km. Rail patronage at Baldock (para 5.12) went up 61% between 2005/6 to 2014/15. Para 5.19 mentions cycle paths in North Herts including Baldock but those referred to are mainly for leisure. Traffic demand in the A1 corridor may increase by 30% by 2031. No traffic surveys on the A507 have been carried out by NHDC for development of this Local Plan. It has not been included in any meaningful traffic modelling exercises during research and forward planning. 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. [Type text] 5. Baldock's railway station is on the northern edge of the town with few houses lying to the north of the railway line. A major development on this side of the railway line would result in a pinchpoint for traffic at the WhiteHorse St/ Station Road intersection. The AECOM's technical note, table 4.1, identifies this crossroad and Letchworth Gate at the southern end of Baldock as problems (above capacity, unacceptable queuing) by 2013 even without further development. The Plan acknowledges that "not all" traffic from BA1 will have to use the Whitehorse St/Station Rd crossroads (4.179) but this also acknowledges that a good proportion of it will. The Plan makes employment provision at above modelled levels SP3, 4.26 and this could increase traffic flow between Baldock and Letchworth and Hitchin. The plan stresses how interconnected Baldock Letchworth and Hitchin are (paras 2.31, 4.27, 13.14) and that many residents commute out (4.25, 4.26). This will lead to more peak hour traffic. Since it is expected that most new Baldock residents will commute to work outside Baldock, as well as extra pressure on the roads there will be unacceptable pressure on the railway.
The station is small and would need extending to accommodate more passengers and the longer trains needed for them. Govia are currently holding their own consultation on their future rail provision and intend to cut "fast" trains stopping at Baldock other than at peak rush hours. This will not serve 7-8000 extra people well. Moreover British Rail had not till recently known of 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 foreward 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.
Where will these new residents work and how will the land designated for industrial development be used? There are few new work opportunities here so most will commute out of Baldock. This will have a massive impact on roads and railways which are already overburdened and close to breaking point. Should areas closer to centres of employment such as West of Stevenagenot be considered.
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 pinchpoint for traffic and a pulling apart of the community. Developments should "be expected to work closely with those directly affected by the proposals to evolve designs that take account the views of the community (NPPF 66) but NHDC have not done this. They have not sought the views of existing residents. "By designating Local Green Space local communities will be able to rule out new development other than in very special circumstances". But NHDC have decided to locate many sites including BA1 on Green Belt land going in the face of this policy. They have not provided appropriate justification for redesignating Green Belt land as they should, showing "exceptional circumstances". Indeed the area BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as shown in NPPF chapter 9. It is good quality agricultural land and of great importance for feeding the local area. "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use poorer areas of land in preference to that of a higher quality NPPF 112.
The impact on local wildlife has also been ignored. Many rare species of birds including corn buntings breed and are resident in this area. Corn buntings are protected in the UK under the Wildlife and Countryside Act, 1981, classified in the UK as a Red List species under the Birds of Conservation Concern review and as a Priority Species in the UK Biodiversity Action Plan.
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.
I should like to be kept updated on the Plan's progress I should like to be invited to the Public Hearing.

Now that NHDC has decided that it does not intend to develop an equitable Local Plan across North Herts and that Baldock will take a disproportionate number of the new housing which will result in the town being doubled in size, there are a number of questions and considerations that arise with such a large increase which need to be carefully considered and answered before the development commences.

Firstly and most importantly the proposed road network for Baldock is weak and undefined and will be totally inadequate for the number of new houses proposed. The bottle-neck problems today are well known particularly at the Whitehorse Road / Royston Road crossroads and also on the A1 south around Stevenage. A new road connecting the A507 London Road to the A505 Baldock bypass including a new bridge across the railway and some tinkering around the station area will not provide the road infrastructure that will be required from three thousand new homes and as a consequence in excess of four thousand additional vehicles.

Has anyone associated with the Local Plan considered where these new homeowners might work and how will they travel to their work and what the impact will be on roads in and around Baldock. It is most likely that people will work either south or west of Baldock given the limited employment opportunities to the east or north. There are no provisions in the Local Plan to address these requirements, which render it unsatisfactory and ineffective as it stands. These needs must be addressed as a matter of priority if this Local Plan is seriously to be pursued.

The proposed development of 2,800 new homes to the north of Baldock is effectively the development of a 'new town' adjacent to the oldest market town in North Herts and therefore, the planning must be considerably more robust and effective than has been identified in the Local Plan. Areas of weakness relate to road infrastructure, water and sewerage provision, employment provision, infrastructure and its funding, greenspaces and landscaping of the 'new town'.

Furthermore what provisions have been made for the retention of the community based culture that currently exists in Baldock?............the answer....... none whatsoever.

My request is for the Local Plan to be withdrawn in order that all or at least some of these issues are adequately addressed.

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Now that NHDC has decided that it does not intend to develop an equitable Local Plan across North Herts and that Baldock will take a disproportionate number of the new housing which will result in the town being doubled in size, there are a number of questions and considerations that arise with such a large increase which need to be carefully considered and answered before the development commences.

Firstly and most importantly the proposed road network for Baldock is weak and undefined and will be totally inadequate for the number of new houses proposed. The bottle-neck problems today are well known particularly at the Whitehorse Road / Royston Road crossroads and also on the A1 south around Stevenage. A new road connecting the A507 London Road to the A505 Baldock bypass including a new bridge across the railway and some tinkering around the station area will not provide the road infrastructure that will be required from three thousand new homes and as a consequence in excess of four thousand additional vehicles.

Has anyone associated with the Local Plan considered where these new homeowners might work and how will they travel to their work and what the impact will be on roads in and around Baldock. It is most likely that people will work either south or west of Baldock given the limited employment opportunities to the east or north. There are no provisions in the Local Plan to address these requirements, which render it unsatisfactory and ineffective as it stands. These needs must be addressed as a matter of priority if this Local Plan is seriously to be pursued.

The proposed development of 2,800 new homes to the north of Baldock is effectively the development of a 'new town' adjacent to the oldest market town in North Herts and therefore, the planning must be considerably more robust and effective than has been identified in the Local Plan. Areas of weakness relate to road infrastructure, water and sewerage provision, employment provision, infrastructure and its funding, greenspaces and landscaping of the 'new town'.

Furthermore what provisions have been made for the retention of the community based culture that currently exists in Baldock?............the answer....... none whatsoever.

My request is for the Local Plan to be withdrawn in order that all or at least some of these issues are adequately addressed.

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Comment on Draft District Local Plan
In his consideration of the Draft Local Plan, I ask the Inspector to consider whether the proposed plan takes account of the changes in the structure of north east Hertfordshire since the Green Belt, protecting the three settlements of Hitchin, Letchworth and Baldock, was established.
Prior to Local Government reorganisation of 1974, which brought into being the District of North Hertfordshire, Hitchin, Letchworth and Baldock were seperate administrative areas with their own Councils. With the establishment of North Herfordshire, these three towns became the main population, employment and service centre for the Distict. They are the sustainable heart of North Hertfordshire, where the main population lives and works and the only area with sustainable public transport and services. It is around these three towns that the District's future expansion should focus.
Is the Green Belt protection of land between these three towns still valid or should it be reviewed to reflect the reality of North Hertfordshire as it now is? The Green Belt is being eroded, in 1997 the A1M Baldock bypass opened, cutting through the Green Belt between Letchworth and Baldock and effectively preventing merger of the two settlements. More recently, the newly built rail loop for the Cambridge rail line has cut into the Green Belt between Hitchin and Letchworth. This area may see further rail development, if the proposed Varsity line between Cambridge and Oxford is routed onto the East Coast main line via the Cambridge branch.
If Green Belt protection was removed from the land between Hitchin and Letchworth and between Letchworth and Baldock, it is probable sufficient land would be released and the proposed development to the north-east of Baldock would not be required. The proposal BA1 does not meet the policy requirement for sustainability, being a new settlement in an area without any supporting infra-structure.
I have no further comment on the Plan as such, except to say that after nearly 20 years and many responses to the various documents that have been put out for consultation over the period, the Council appears to have taken little account of public comment. It appears only to have listened to land-owners, who proposed land for possible development. The Draft Plan includes many sites where development has already started and in many cases has been completed or permission granted. Others where developers are already using the draft plan as the basis for pre-application discussions and work.
In Royston all sites are either built, development permission has been granted or there are advanced stages of pre-application consultation. In Baldock preliminary archeological surveys have already started on the major site to the north-east of the town, BA1.
In fairness the Council are obliged to produce a District Plan and consult, but for the public the process is a farce.

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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 one of the "Tests of Soundness" that Local Plans are required to meet:
"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
It is shown below that Baldock is already struggling with over-stretched amenities and major traffic congestion. 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 the planners are simply ignoring.
1. Traffic congestion in Baldock town centre
Traffic access into Baldock is restricted by both the railway line and the A1(M). As a result, a very large proportion of traffic entering or leaving Baldock is forced to cross one particular road junction in the town centre. This junction pre-dates the A1 and the railway by hundreds of years and was never intended to carry anything like the current volume of traffic.
The junction in question is the one where the A507 North Road meets the Royston Road (the old route of the A505) at the junction of Whitehorse Street, Station Road, Royston Road and Clothall Road. This junction is used by:
* Traffic entering Baldock from the north west on the A507; * Traffic entering Baldock from the north on the A1; * Traffic entering Baldock from the north from Bygrave, Ashwell, Steeple Morden, Guilden Morden and all the surrounding villages; * Traffic entering Baldock from the north east on the A505; * Traffic entering Baldock from the south east on the A507.
All these major traffic flows entering Baldock - plus all the corresponding traffic flows heading in the opposite direction - have to pass through this single junction. As a result, the junction is always congested, and congestion during the rush hour can extend back almost as far as the Baldock services. Air pollution levels between the railway bridge and the junction are particularly high during the rush hour, and are probably higher than anywhere else in Baldock. It was stated during public meetings to consider the draft Local Plan that Baldock has an existing air quality problem, and that the "Baldock bowl" concentrates particulates from traffic exhausts.
The fact is that there is no simple solution to this problem, which is why nothing has been done about it. The approach has been to avoid doing anything that makes the problem any more critical than it already is, which is why building 2,800 houses on the Blackhorse Farm site is about the worst possible thing that could happen in this part of Baldock. Planning should be about enabling the town to expand in a sustainable way, but adding approximately 5,600 cars to an area that is already massively congested will simply lead to gridlock and will further exacerbate the air pollution problem. Objective 2(c) of the Sustainability Appraisal Framework includes the sub-objective: "avoid exacerbating local traffic congestion", but it appears that this requirement has simply been ignored.2
Surprisingly, the Draft Sustainability Appraisal by CAG Consultants3 does not appear to mention this problem, although it does include some generic concerns about traffic such as:
"The density of traffic on the principal road network is high and increasing but the rural nature of the District makes the provision of sustainable travel modes more challenging."
In a response to the consultants' findings, North Herts District Council stated that:
"Detailed policies and / or Transport Assessments (or equivalent) at planning application stage will ensure these issues are considered".
I find it incredible that such a major problem has not yet been addressed by the planners. Since the Blackhorse Farm development will have a massive impact on traffic congestion, the National Planning Policy Framework clearly requires a Transport Assessment to be produced. This is defined as:
"A comprehensive and systematic process that sets out transport issues relating to a proposed development. It identifies what measures will be required to improve accessibility and safety for all modes of travel, particularly for alternatives to the car such as walking, cycling and public transport and what measures will need to be taken to deal with the anticipated transport impacts of the development."
I can see no possible way in which a Transport Assessment that meets these requirements could be produced for the Blackhorse Farm site. Deferring this issue until the planning application stage is simply kicking the issue into the long grass, and prevents scrutiny by the Planning Inspector.
2. Access to Baldock Station
The problem described in the previous section is made considerably worse by the unfortunate fact that Baldock Station is located between the congested traffic junction and the barrier formed by the railway embankment. As a result, traffic heading towards the station has three options:
Approach from the north via Station Road. This traffic has to pass through the constriction formed by the railway bridge, and this area is always massively congested during the rush hour. *
Approach from the south via Station Road. This traffic has to cross the congested traffic junction that was discussed in the previous section. *
Approach from the west via Icknield Way or Football Close. Both of these are residential streets with extensive on-road parking, so they are effectively only one car wide.
During the evening rush hour, the arrival of each train from London frequently creates dangerous situations at the bottom of the station approach road as cars from the station try to force their way into the traffic and face resistance from frustrated motorists who have spent a long time in the queue. Cars turning right have to undertake a particularly dangerous manoeuvre.
Despite the suggestions of the planners that a high proportion of "affordable" housing will be included in the development, there is very little evidence that employment in Baldock will grow sufficiently to accommodate this influx of new workers, or that the jobs will be sufficiently highly paid to allow people to pay for these homes. The location of the Blackhorse Farm development so close to Baldock Station inevitably means that many of the houses will be sold to people who commute to London or Cambridge. It was admitted at one of the planning meetings that the developers might try to buy their way out of affordable housing commitments so that they could focus on selling to affluent commuters. If this occurs, then existing congestion problems will be made far worse.
When Cllr. Levett was asked about this at a meeting on 12th July 2016 at Knights Templar School, he said that they were looking at walking and cycling options. It was pointed out to him that the railway bridge on North Road is only marginally wider than two cars, so the only cycling option is to sit between stationary cars in a traffic jam. The walking options are not much better because the pavements under the bridge are extremely narrow. At this point, he declared that this was not a planning problem.
Once again, a fundamental weakness in the Local Plan is simply being kicked into the long grass. 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.
3. Capacity restrictions at Baldock Station
The National Planning Policy Framework requires a Transport Assessment that emphasises "alternatives to the car such as walking, cycling and public transport". Clearly, the railway is a major component of the public transport provision in Baldock, so it is important to consider whether it has the spare capacity to carry the additional traffic that would be generated by new developments in and around Baldock.
Baldock only has a small station, and many rail travellers are already forced to stand all the way to London. Unfortunately, the additional capacity required in the rail network simply does not exist, and would be massively expensive to create. One of the key constraints is the cost of upgrading the Welwyn Viaduct and the Welwyn tunnels from two tracks to four.
The "Draft Sustainability Appraisal of North Hertfordshire Proposed Submission Local Plan" by CAG Consultants suggests that high density developments should be allowed in close proximity to town centres or railway stations. However, this pre-supposes that the railway station has the spare capacity needed to carry the additional passengers that will be generated by the development. In the case of Baldock Station, there is no realistic expectation of any new capacity becoming available.
Indeed, exactly the opposite seems to be happening. Under plans announced by Govia Thameslink in their 2018 timetable consultation, Baldock is set to lose semi-fast services to and from London in order to free-up capacity for services to other places further up the line with even more pressing needs. They will also be replacing the existing trains with newer models that provide air conditioning - but 30% fewer seats. Far from the integrated approach to housing and transport planning advocated by Paragraph 31 of the National Planning Policy Framework
"Local authorities should work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development"
the local authority and the transport provider in Baldock are working against each other to make the situation far, far worse.
4. Proposed new road connecting A507 and A505
Although the NHDC planners have not produced a Traffic Assessment for the Blackhorse Farm development, they have proposed a road linking the A507 north of Baldock to the A505 east of Baldock. Paragraph 4.179 of their "Final draft of the Local Plan" states:
"The site is also large enough to support new schools, local facilities and a new link road, including an additional road bridge over the railway so that not all traffic has to use the Station Road bridge and the Whitehorse Street/Royston Road crossroads."
In other words, the road would allow some traffic to avoid the junction that is discussed in Section 1 above. However, it is not explained how this link road will address the needs of the Blackhorse Farm development. People living on the new development are hardly likely to drive across to the other side of the railway line so they can then enter Baldock via the same gridlocked junction from the east instead of from the north.
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 below the level of the surrounding development. Since the railway is already raised on an embankment in this area, a bridge over the embankment would have a major noise and visual impact on the surrounding area.
It should therefore be a condition of this development that the road passes under the railway line (in a tunnel) rather than over it (via a bridge). For the residents of the new development and the existing residents of Lower Bygrave, the design of this road and the associated railway crossing is a critical issue.
During the Council Meeting on 24th July 2016, Cllr Levett said that the new road would probably join North Road near the turning for Radwell. However, he also said that they were forced to plan this development on Herts County Council land because no other land had been made available. I do not know whether it would be possible to bring the road as far north as the Radwell turning without leaving Herts CC land. If it has to be brought out further south, it would cause even more congestion during the rush hour and would presumably require existing houses to be demolished.
Another problem with this road is that it effectively accepts that the Blackhorse Farm development can never become an integral part of Baldock. As explained in Sections 1 and 2 above, the railway and the traffic junction form a bottleneck between the new development and the centre of Baldock, and the proposed new road will do absolutely nothing to fix this. As a result, Baldock will develop like an hourglass with two physically-close but largely separate town centres linked by a narrow constriction. There is a real risk that the new road will mean that the Blackhorse Farm development will develop a closer affinity with towns such as Stotfold - which would only be about 2 miles away and linked by a fast road. Although the development would lie within the boundary of Baldock, it would be a ghetto having little involvement with the life of the town. This flies in the face of Section 2 of the National Planning Policy Framework which requires new developments to promote the vitality of associated town centres, and talks about developing on "accessible sites that are well connected to the town centre".
Baldock is one of only five Hertfordshire towns classed as being of national importance for its historic character, and the town centre contains over 100 listed buildings. Nobody - not even the NHDC planners - claims that the Blackhorse Farm development will enhance Baldock town centre.
5. Inadequate local amenities to support existing needs
The number of houses allocated to Baldock will increase the population by 83%. Rather than seeking to preserve the character and heritage of this historic market town by sensitive and carefully planned development, it has simply been used as a dumping ground for a large number of houses in order to meet an unrealistic quota. The scale of development around Baldock is so far out of alignment with the current size of the town that it will inevitably place massive additional pressures on local amenities that are already overstretched.
At local planning meetings, NHDC planners have been bombarded with questions and complaints about inadequate local amenities. Schools, doctors' surgeries and other basic amenities are already at full capacity. Even water supplies are inadequate (Affinity Water describes our area as being under "serious water stress", and there have been a number of incidents where residents of Upper Bygrave have lost water supplies completely).
During a discussion about the alternative option of a new garden city (as proposed by the local MP, Sir Oliver Heald) it was pointed out that a new city would at least start from a position of no amenities, but a massive development at Blackhorse Farm would be put in an area where the amenities are already in deficit. Furthermore, we can be certain that developers will build houses before building any amenities, so the situation will have to get considerably worse before any action is taken.
Paragraph 177 of the National Planning Policy Framework states that:
"It is equally important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan. Any affordable housing or local standards requirements that may be applied to development should be assessed at the plan-making stage, where possible, and kept under review."
The Local Plan should not be accepted until residents' concerns about local amenities have been fully addressed.
6. Green Belt development
Four of the large "strategic developments" proposed by NHDC, including the Blackhorse Farm development, have been located on Green Belt land. Paragraph 80 of the National Planning Policy Framework lists five purposes for the Green Belt:
1. to check the unrestricted sprawl of large built-up areas; 2. to prevent neighbouring towns merging into one another; 3. to assist in safeguarding the countryside from encroachment; 4. to preserve the setting and special character of historic towns; and 5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
Table 5 in the North Hertfordshire Green Belt Review5 provides a "Green Belt Review Assessment Matrix". The Green Belt has been divided into sectors, and each sector is subjectively assessed against the first four of the five Green Belt criteria listed above. However, the table does not provide any assessment in relation to the fifth criterion. This omission is interesting, because I have seen very little evidence of urban regeneration in this Local Plan.
The proposed Blackhorse Farm development to the north of Baldock is a classic example of urban sprawl, and is exactly the kind of rapacious development that the Green Belt was intended to prevent. Paragraph 41 of the North Hertfordshire Green Belt Review states that
"Checking unrestricted sprawl of large built-up areas is a component of areas adjoining the three major settlements in North Hertfordshire. This explains the significant contribution
5 North Hertfordshire Green Belt Review 2014, Part 1: Assessment of current Green Belt and Potential Development Sites in the Green Belt.
scores for all areas surrounding the settlements of Hitchin, Letchworth, Baldock and Knebworth."
I feel very strongly that we should be doing everything in our power to protect the Green Belt - particularly since there are other sites available that DO meet planning criteria and are NOT in the Green Belt. According to the Department for Communities and Local Government's planning guidance:
"The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open .. inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances. When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. 'Very special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations."
It was stated at the meeting of North Herts District Council on 27th November 2014 that the council has no option but to develop on the Green Belt because they are required to meet housing targets set by the government. However, I have read the ministerial guidance on development in the Green Belt published by Communities Secretary Eric Pickles and Housing & Planning Minister Brandon Lewis on 6th October 2014, and it makes it clear that councils are NOT required to build on the Green Belt just so that they can meet housing targets. At the council meeting on 27th November, councillors consistently stated that they were being forced to develop the land to the north of Baldock, when it seems to me that they are specifically PREVENTED from doing this. My understanding from the meeting was that NHDC believe that they can ignore the ministerial guidance and propose a Local Plan in which most of the construction will be on Green Belt land.
The council also claimed at the same meeting that they can get around the Green Belt problem by removing the Green Belt designation from land where they want to build and applying it instead to land in other places where they do not want to build. This is clearly not a reasonable interpretation of the rules. If it was, then the Green Belt would become completely pointless because it could simply be shifted whenever it gets in the way of development. Maps of the Green Belt in the area indicate very clearly that it was specifically intended to protect the countryside around Baldock and the other local towns - not somewhere else.
The council have claimed that they have no alternative to developing Green Belt land, yet there are other sites available that meet all of the planning criteria and are not in the Green Belt. To my knowledge, the council have offered no explanation as to why these sites have been held back and placed on the reserve list when they should have been prioritised over Green Belt development.
Paragraph 79 of the National Planning Policy Framework states that
"The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence."
In spite of this, a large proportion of the development proposed in the Local Plan is on Green Belt land, suggesting that the Green Belt in North Hertfordshire is not permanent at all. Furthermore, the proposed Blackhorse Farm development is a classic case of urban sprawl driven by political expediency - despite the government making it very clear that political expediency does not constitute "very special circumstances". This is exactly the kind of inappropriate development that the Green Belt was intended to stop. It may be a fundamental government aim "to prevent urban sprawl by keeping land permanently open", but it is clearly not an aim shared by NHDC. How can we have any faith in a planning system that allows councils to ignore long-established environmental protections as soon as they become inconvenient?
Conclusions
The scale of the proposed Blackhorse Farm development is well beyond anything that Baldock could reasonably be expected to accommodate. The very large number of houses proposed, and the natural constriction of the transport corridors, indicates that the development would not be an enhancement to Baldock but a competing economy that will suck economic activity out of the town centre. The planners have not described the Blackhorse Farm development as a new town, but that is effectively what it is. Sensitive infill development in appropriate areas of the town would be beneficial, but the urban sprawl that is proposed will lead to massive traffic congestion and make the town centre almost inaccessible to residents in surrounding villages such as Ashwell. Sadly, the proposed development seems to be driven by political expediency rather than by any coherent plan for the sensible development of the town.
Paragraph 32 of the National Planning Policy Framework states that:
All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. Plans and decisions should take account of whether ... improvements can be undertaken within the transport network that cost effectively limit the significant impacts of the development. Development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.
Sections 1, 2, 3 and 4 of this letter demonstrate that the "residual cumulative effects" of the proposed Blackhorse Farm development are indeed severe, and the Local Plan is not supported by any Transport Statement or Transport Assessment for the site. The National Planning Policy Framework therefore requires that the development should be prevented or refused on transport grounds. Deferring the requirement for a Transport Assessment until a planning application has been received effectively bypasses the scrutiny of the Planning Inspector and should not be permitted.
Section 5 of this letter shows that the scale of proposed development around Baldock is so far out of alignment with the current size of the town that it will inevitably place massive additional pressures on local amenities that are already overstretched. The planners have largely ignored residents' concerns about local amenities, but Paragraph 177 of the National Planning Policy Framework clearly
states that "infrastructure and development policies should be planned at the same time, in the Local Plan."
Section 6 of this letter shows that the proposed Blackhorse Farm development is in direct contravention to clearly-stated government policy in relation to the Green Belt. The Department for Communities and Local Government's planning guidance states that:
"The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open .. inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances."
NHDC councillors have stated that they are forced to propose green belt developments in order to meet government housing targets, but the ministerial guidance on Green Belt development published on 6th October 2014 makes it clear that councils are NOT required to build on the Green Belt in order to meet housing targets. The Blackhorse Farm development is clearly urban sprawl, and political expediency does not constitute "very special circumstances". This is exactly the kind of inappropriate development that the Green Belt is intended to stop.
A Local Plan is required to meet four "Tests of Soundness":
1. Positively prepared - the plan should be based on a strategy which seeks to meet objectively assessed development and infrastructure requirements, including unmet requirements from neighbouring authorities where it is reasonable to do so and consistent with achieving sustainable development; 2. Justified - the plan should be the most appropriate strategy, when considered against the reasonable alternatives, based on proportionate evidence; 3. Effective - the plan should be deliverable over its period and based on effective joint working on cross boundary strategic priorities; and 4. Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework.
This letter has demonstrated that the Local Plan fails Tests 3 and 4 because it is not deliverable and does not comply with the policies in the National Planning Policy Framework.
I understand that the previous public consultation on the Local Plan generated over 8,000 replies, proving that there is very strong public opposition to it. Since then, the plan has not been revised in any meaningful way to address the primary concerns of the local residents. It may be late in the process, but now is the time to demonstrate that peoples' views really do matter and this "public consultation" exercise is not just a sham.
The council will no doubt claim that people who object to their Local Plan are "nimbys" who will resist any development. That is simply not the case. We would welcome careful, well-thought-out development of Baldock, but not the wholesale devastation proposed by this Local Plan. For the record, I support the very sensible alternative proposal put forward by the local MP, Sir Oliver Heald.

The Bedfordshire and River Ivel Internal Drainage Board makes the following comments to your proposed Local Plan 2011 -2031 consultation.

The Plan does not adequately address Flood Risk and should be amended to strengthen the requirements of addressing flood risk and development, particularly in the north of the District in Letchworth and Baldock.

Below are some examples of paragraphs which should be redrafted to ensure development does not have a detrimental effect on flooding:

2.29 The Plan states fluvial flooding is not a huge issue. However, Stotfold and Arlesey have experienced significant flooding in the past both from the River Ivel and Pix Brook, which is exacerbated from the run off from Letchworth and Baldock.

2.78 The paragraph must include infrastructure that is required to accommodate growth as SuDS which are strategic, integrated and maintained. This is critical given the scale of development in Letchworth (900+ houses) and Baldock (2800 + houses).

3.6 The spatial vision of high quality sustainable design and managing flood risk needs to refer to the provision of strategic and integrated SuDS, which include effective and funded SuDS maintenance.

4.73 Policy SP7. This infrastructure should include SuDS and flood risk management, such that a public authority can ensure drainage infrastructure operates as designed in the future.

4.131 Policy SP11. It is inadequate to state that this Plan 'seeks'.... when other policy state 'will'. The Policy should state the Plan will deliver the provision of strategic and integrated SuDS that will be maintained.

4.136 For clarity, WFD seeks to meet good ecological "potential" for heavily modified and artificial water bodies, as well as good ecological "status" for natural water bodies.

4.137 The Plan states fluvial flooding is not a huge issue. However, Stotfold and Arlesey have experienced significant flooding in the past both from the River Ivel and Pix Brook, which is exacerbated from the run off from Letchworth and Baldock.

SP14. Downstream of Baldock is Stotfold which has experienced flooding from the River Ivel. This policy must accommodate for this development policy to provide strategic, integrated and maintainable SuDS to reduce catchment flood risk.

SP15. Downstream of Letchworth is Stotfold which has experienced significant flooding from the Pix Brook and the River Ivel. This policy must accommodate for this development policy to provide strategic, integrated and maintainable SuDS to reduce catchment flood risk.

NE7. There is a requirement to reduce the existing flood risk in Stotfold immediately downstream of the urban runoff areas of Letchworth and Baldock, as in SP14 and SP15, this Policy should be strengthened to include mitigation being designed and implemented on development sites to attenuate flows c) and d). It is fundamental that flood risk is minimised and that functional and effective infrastructure is provided that is maintainable in addition to items e).

NE8. This Policy should include strategic, integrated and maintainable SuDS for all sources of flood risk, and not just surface water, particularly given that flood risk exists from the Ivel and Pix Brook. The area is heavily modified with public storm sewers, modified watercourses and large flood attenuation reservoirs (Pix Brook), so any solution for development needs to be appropriate to the scale of development, rather than simply mimic the natural drainage pattern.

NE8 and 11.59. For developments draining in the Ivel and Pix Brook catchment, the Council and developers should also consult the IDB, as well as the Lead Local Flood Authority and the EA.

NE9. For any development in the Bedfordshire and River Ivel IDB district, a developer will be required to comply with the Board's Byelaws including maintaining a minimum 7 m wide undeveloped buffer zone for ordinary watercourses and applying the land drainage consenting regime.

I trust you find the Board's comments clear and informative.

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I strongly object to the current NHDC Local Plan particularly regarding Baldock for the following reasons:

* The needs and wishes of the people of Baldock have been ignored.

* The Government has reduced the need for 14,400 houses in North Hertfordshire to 13,800 so why is NHDC still pressing ahead with its plan to build the former number? What has it done to question the real need for this number bearing in mind that these numbers are decided on in an office far removed from North Hertfordshire?

* Where are all these new people going to work - London, Cambridge, Stevenage? How will they get to work?

* Trains are already overcrowded at peak times. We now know that the capacity of the trains is to be reduced by the train operator - how does this match up with hugely increasing numbers of people needing to use the train service which will be the inevitable result of building 3,290 houses in Baldock?

* If the trains cannot accommodate thousands more commuters then inevitably travel by road is the only option for many. The A1 is already gridlocked at times - what does NHDC propose to do about this? Are our villages to become 'rat runs' - what is NHDC doing to ensure this does not happen?

* No-one from the proposed housing between Bygrave and Baldock will walk into Baldock. It is already difficult to find a parking space in Baldock and there is now a plan to increase the size of parking spaces to accommodate the current vogue for larger cars with the inevitable result of reducing the number of parking spaces. So, what is NHDC doing to increase the number of parking spaces for the thousands more cars their Local Plan will release on to our roads?

* It is already difficult to get a place at Knights Templar School - what is NHDC proposing to do to increase school places at both secondary and primary level?

* GP surgeries and hospitals are already experiencing an unprecedented demand on their services which they are having difficulty in managing. Has NHDC got a plan to increase capacity as they double the number of people needing to use medical facilities?

I would very much appreciate an answer these questions.

See attached

I wish to object to the Local Plan as I consider it NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.
General comments for the Baldock area (especially sites BA1/BA2/BA3)
Baldock is a small town and is ill-prepared for the high level of expansion that this proposed plan would entail. It is disproportionate that Baldock has such a high proportion of houses allocated compared to other towns in the area.
The sites around Clothall Common area (BA2/3) need to be treated as one site and a separate masterplan for the area to be prepared to consider fully the whole area. This must include additional doctors and schools to be in place as the first houses are completed. School places in particular are already a problem without any additional houses being built on any site in Baldock (when my daughter started school in 2014 many children were allocated schools outside Baldock as there were 32 too few places within Baldock).
"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 at any site 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.
All houses to be built should have room for at least 2 cars.
Suggested changes:
Reduce the housing allocation for Baldock and allocate some of this to other sites in the other towns in North Herts. Consider also an entirely new settlement elsewhere away from the 4 towns.
Treat all sites in Clothall Common area as one site and create master plan for the area to include doctors and schools.
All houses to be built should include parking for at least 2 vehicles.
Infrastructure planning and timescales should be in place before building starts; detailed investigations of all aspects (especially traffic) must be carried out for the plan to be approved.

Specific comments
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 NOT JUSTIFIED 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 NOT JUSTIFIED as it is not the most appropriate strategy.

3. Baldock is situated in a valley and air pollutants are known to be trapped and concentrated in Baldock. The traffic levels in Hitchin Street and Whitehorse Street are already causing the level of pollutants to be in danger of exceeding EU permitted levels (para 9.28). The number of extra vehicles associated with the increased number of homes and services in and around Baldock will cause these levels to be surpassed and will affect the health of the people of Baldock (particularly with regard to respiratory disease). The Housing and Green Belt background paper notes that former site 209E (Priory Fields Hitchin) was considered unsuitable for exactly this reason.
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

4. The roads pose a major obstacle for this plan. The crossroads where Whitehorse Street, North Road, Clothall Road and Royston Road meet are heaving with traffic for much of the day. There are frequent queues. Almost all of the traffic coming through Baldock passes through this crossroads. There is no way to expand this crossroads because it has listed buildings on it. It is already the case that Raban Court has been hit several times by lorries turning left from North Road (A507) to Royston Road (B656).
Traffic coming to and from the station and the houses on Icknield Way East further impacts the pinch point at this junction. In addition the railway bridge over the A507 is hit frequently by lorries and this causes disruption on the roads while everything is cleared up. Delays also occur when lorries realise that they cannot fit under the bridge and have to perform manoeuvres to turn around.
The proposed miniroundabout at Whitehorse St / Station Rd crossroads, the only mitigation planned for Baldock (AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction.
The 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.
Traffic modelling has not been carried out sufficiently to prepare for the potential impact of building so many houses on the BA1 site. With 2-3 vehicles projected per house and almost all people working outside Baldock (and many of them using the B656/A507 crossroads) the implication is that an extra 5000-7000 vehicles may be on our roads and many of those would be coming down to this already heavily congested junction. The proposed link roads will not reduce the pressure on this junction or other parts of Baldock enough. The junction of the High Street with Hitchin/Whitehorse Street is another part of Baldock where air pollution and traffic levels cause concern.
The Plan is NOT JUSTIFIED 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. As most new Baldock residents will work outside Baldock the railway station would also need expanding to accept an 80% rise in commuters and the longer trains that would be needed. The current proposal (in consultation at the moment) to cut fast off-peak services to Baldock will not make Baldock desirable to people as a place to live.

The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on transport and local highway network. There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.

6. The Plan does not retain and enhance the town centre of Baldock as recommended by the NPPF (para 23). Building a new development BA1 on the other side of the railway line to the main part of town would divide the community and will cause traffic problems. "By designating Local Green Space, local communities will be able to rule out new development other than in very special circumstances". 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 showing what "exceptional circumstances" there are that necessitates building on the Green Belt. Site BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as in NPPF chapter 9. "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) - the land at BA1 is high quality land.

7. The provision of sewerage and potential risk of flooding over this vast site has not been fully investigated. The details of the protection of the Ivel Nature reserve are not clear; neither is it clear how other wildlife will be protected such as the endangered corn bunting on BA1.

8. Insufficient green spaces such as parks have been provided and there are no details of extra leisure facilities within Baldock.

The Plan is NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.

Suggested changes (site BA1):

* Reduce size of site to enable transport and community to cope
* More equitable distribution of houses across North Herts
* Reduce number/density of houses to reduce flood risk and protect wildlife
* Additional railway parking
* Additional town centre parking
* Require site to include at least two large children's play parks and parking to allow people to visit them.
* 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.
* Tree planting along every public road
* Ensure houses have sufficient parking (2 cars per house minimum)
* Build key infrastructure in advance of allowing new building (link road to ensure that construction traffic does not have to go through existing road network pinch points.)
* An additional large green space with ample parking to be provided as part of the new development in order that Baldock has a facility which can cater for both increased demand and the need to drive to its location.
* Plan to include sports facilities.
* Work in partnership with the rail companies 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) in order that it can cater for the increased demand.

I wish to be kept informed about the plan.
I do not wish to appear at the oral examination.

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

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

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

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

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

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

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

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

If you have any queries, please let me know.

See attachment

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

The Plan is NOT CONSISTENT WITH NATIONAL POLICY.

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

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

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

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

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

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

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

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

I am writing in response to the proposed Local Plan for Baldock in North Hertfordshire. I have presented my response below by referring to the National Planning Policy Framework and the Local Plan.

SP6 Sustainable Transport
With regard to the BA1 North of Baldock site, traffic congestion on the A507 has always been an enormous problem and it has been exacerbated since the opening of the Baldock by-pass in 2006. Increased traffic on the A507 from the BA1 site would encourage vehicles to use the single track Nortonbury Lane to access the town and severely compromise the safety and nature of this lane. A further concern is the dangerous double bend on the A507 at Mill Valley (that often becomes flooded in heavy rains) which would put at risk traffic and pedestrians using any proposed access road onto the BA1 site. The town has been described as an hourglass, with the crossroads of A505 and A507 at the pinch point, its centre. The listed buildings (dating back to the 1500s) at the junction make finding a solution virtually impossible. There are already tailbacks from this junction back along the A507, bordering the site where the BA1 North of Baldock site is planned. This occurs at most times of the day and particularly during morning and evening peak times. This has also been exacerbated by Sat Nav companies guiding lorries and other traffic along the A507 and through this junction. The traffic will increase by approximately 7000 cars generated from the new housing development as well as any additional commercial traffic. I attach photos taken on two consecutive days showing typical traffic jams stretching back along the A507 (from the junction with the A505). These are taken where the A507 borders the proposed BA1 north of Baldock site. All the town's amenities are at the other side of the town to the BA1 development and this will mean that cars will have to cross the very congested A505/A507 junction and add to the already heavy congestion to get to the town centre. NPPF Section 4 'Promoting Sustainable Transport' paragraph 32, states that 'All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment'. There are no detailed plans for reducing the impact of traffic from the North of Baldock site (BA1) on the A507/A505 Junction, except for a mini-roundabout and phased lights. The Station Road/North Road Railway bridge on the busy A507 is already being regularly damaged by the volume of heavy goods traffic, and the impact of more cars/pedestrians has not been fully assessed. The road under the bridge cannot be widened to accommodate the increase in traffic. There are two very narrow pedestrian ways under the bridge that cannot be widened to accommodate the increase in pedestrians walking to the station from the BA1 site. Pedestrians would be put at risk when using the two narrow footpaths under the bridge, indeed there have been pedestrians injured (including children) trying to use these footpaths in recent years.
The A1 is becoming significantly more congested due to a large number of houses that are being built in Biggleswade (which is just 8 miles north of Baldock on the AI). The addition of the proposed 7000 vehicles from Baldock would add to this congestion causing North Herts to become gridlocked during peak times.
At least a second rail crossing and a link road would have to be an essential part of a local plan. The plan mentions that the proposed site will need a new link road, including an additional bridge over the railway so that not all traffic has to use the Station Road/North Road bridge and A505/A507 Junction with its vulnerable historic buildings. However, the local sustainability transport assessment does not consider North Baldock in the traffic modeling, and local Plan Model Testing 60271338 states that Baldock and Letchworth have not been tested to date. Local Plan SP14 4.180 says safe access will be needed to the north of Baldock but doesn't say how it will be achieved. There is also mention of Southern link road in B3 and B4 but no details are given. The Plan is not effective as it cannot be delivered in the plan period. It also fails consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work. Road links to the east and west are wholly inadequate and links north and south are already severely congested particularly at peak times. The local plan makes no mention of improvements to these road links. The mini-roundabout is the only cost included in the plan for Baldock despite the clear need for major transport projects, such as a new crossing with the railway and major roadways that would be required to divert at least some of the extra 7000 vehicles away from the A505/A507 junction.
There are severe doubts over the capacity for the railway to take a potential doubling of passengers (from new housing development) at Baldock train station. Commuters from the new development BA1 will require quick, safe and efficient access to the station. NPPF Paragraph 32 states that safe and suitable access to the site should be provided for all transport users. The railway station itself will need to be enhanced with additional services and facilities. Govia, the train service provider, is conducting its own consultation about changes to timetabling and new services starting in 2018 but there had been no communication up until November 2016 between NHDC and Govia relating to the proposed Local plan. The plan makes no significant points other than the convenience of location near to a station. NHDC has not consulted with Govia during the course of the preparation of this local plan. Currently, Govia is planning to reduce the service to Baldock at off-peak times. NPPF Paragraph 32 goes on to state that development decisions should take account of whether improvements can be undertaken within the existing transport network. NPPF paragraph 32 states that all developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. The Local Plan is therefore not effective as it cannot be delivered in the plan period. It also fails the national policy test as it does not properly assess the required transport improvements.

SP7 Infrastructure requirements and developer contribution
There are doubts over the provision of schools, health and recreational facilities and when they will be provided. Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered 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. The local plan 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.

SP12 Green infrastructure, biodiversity and landscape
Ivel Nature Reserve Baldock as a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is valued by locals and benefits greatly from the surrounding farmland. The 1979 Act (Scheduled Ancient Monuments) emphasises the need for care with planning consent in these instances. In addition, the BA1 site is designated as being of archaeological interest and is consequently subject to additional planning requirements.
In the Local Plan, sustainability appraisal notes identify BA1 to have moderate to high landscape sensitivity. NPPF 118 states: When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused; proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made if the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest. Local people are extremely concerned that this has not been adequately addressed in the local plan.

SP13 Historic environment
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. The historic market town of Baldock cannot sustain the proposed 80% growth; the unique character of the town would be lost for ever. It is very possible that Baldock is likely to become two towns with limited integration of social and economic communities. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive communities. Local Plan Paragraph 4.38 states that the District contains a range of retail and service centres, from medium sized towns to small village and neighbourhood centres. Each one performs a particular role to meet the needs of its catchment population, and is part of a network of centres within the District, and the Council is committed to protect the vitality and viability of all centres. Paragraph 4.44 notes that the growth of the District will require additional centres to be provided to serve BA1 and the large developments at Baldock. This will require more than just a large housing estate. Moreover, NPPF Paragraph 126 states that local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account: the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; the desirability of new development making a positive contribution to local character and distinctiveness; and opportunities to draw on the contribution made by the historic environment to the character of a place. In this regard increasing the size of Baldock by 80% (3,500 houses) will put its significant heritage assets at great risk.

SP14 Site BA1 North of Baldock
There are doubts over the provision of schools, health and recreational facilities and when they will be provided. Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered 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. The local plan 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.
Ivel Nature Reserve a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is well greatly valued by locals and benefits greatly from the surrounding farmland.
The BA1 site is Green Belt to the north of Baldock. It has been designated Green Belt to protect the northern boundary of the town and to preserve the setting and special character of the historic town of Baldock. The BA1 site is very well established quality and accessible agricultural land that has been devotedly farmed for many decades. If the BA1 site goes ahead this prime agricultural land will be lost for ever. There are many small holdings that will lose their land which has been handed down from generation to generation. Small farmers will lose their livelihood. There are doubts over whether adequate consideration has been given to available brownfield sites before building on Green Belt. The BA1 North Baldock housing site has been designated purely on the basis that it is land currently owned by Hertfordshire County Council and therefore cheaply and easily acquired. There is no evidence to show that other sites were considered, and there is no assessment to show that this is the most suitable site for a development of this size. No other consideration has been given to justifying why the site north of Baldock is the best one available. Furthermore, the planned development at Baldock is vastly disproportionate to that which is planned for Letchworth and Hitchin, which are both significantly larger towns. Other land owners are prepared to put their land forward for development, however they have not been considered.

D4 Air Quality
Baldock is located in a bowl in the lee of the low lying Chiltern chalk hills, where pollution nests and can lead to health problems such as asthma and other breathing problems. It is essential that an assessment is carried out on the pollution impact of the extra 7000 vehicles that will pass through Baldock. Also, particulates from tyres and brakes cause pollution making roundabouts particularly bad. Notably, in paragraph 9.28, the plan notes that air quality standards are already close to being exceeded in Whitehorse Street and Hitchin Street in Baldock. The Housing and Green Belt Background paper notes that former site 209E (Priory Fields in Hitchin) was considered unsuitable for building on for the same reason. NPPF Paragraph 124 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, as it fails the criteria in that it is not consistent with national policy on air quality limits.

SP4 Town and Local Centres
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. The historic market town of Baldock cannot sustain the proposed 80% growth; the unique character of the town would be lost for ever. It is very possible that Baldock is likely to become two towns with limited integration of social and economic communities. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive communities. Local Plan Paragraph 4.38 states that the District contains a range of retail and service centres, from medium sized towns to small village and neighbourhood centres. Each one performs a particular role to meet the needs of its catchment population, and is part of a network of centres within the District, and the Council is committed to protect the vitality and viability of all centres. Paragraph 4.44 notes that the growth of the District will require additional centres to be provided to serve BA1 and the large developments at Baldock. This will require more than just a large housing estate. Moreover, NPPF Paragraph 126 states that local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account: the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; the desirability of new development making a positive contribution to local character and distinctiveness; and opportunities to draw on the contribution made by the historic environment to the character of a place. In this regard increasing the size of Baldock by 80% (3,500 houses) will put its significant heritage assets at great risk.

NE1 Landscape
Ivel Nature Reserve a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is valued by locals and benefits greatly from the surrounding farmland. The 1979 Act (Scheduled Ancient Monuments) emphasises the need for care with planning consent in these instances. In addition, the BA1 site is designated as being of archaeological interest and is consequently subject to additional planning requirements.
In the Local Plan, sustainability appraisal notes identify BA1 to have moderate to high landscape sensitivity. NPPF 118 states: When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused; proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made if the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest. Local people are extremely concerned that this has not been adequately addressed in the local plan.

NE8 Sustainable drainage systems
Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable.

NE9 Water Quality and environment
Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered 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. The local plan is not consistent with national policy as it has not assessed the costs of providing the necessary infrastructure at Baldock and assumes that costs will be met by developers.

SP5 Countryside and Green Belt
The BA1 site is Green Belt to the north of Baldock. It has been designated Green Belt to protect the northern boundary of the town and to preserve the setting and special character of the historic town of Baldock. The BA1 site is very well established quality and accessible agricultural land that has been devotedly farmed for many decades. If the BA1 site goes ahead this prime agricultural land will be lost for ever. There are many small holdings that will lose their land which has been handed down from generation to generation. Small farmers will lose their livelihood. There are doubts over whether adequate consideration has been given to available brownfield sites before building on Green Belt. Contrary to the NPPF paragraph 80 point 4, which lists one of the main purposes of the Green Belt is to preserve the setting and special character of historic towns like Baldock (the oldest historic town in North Hertfordshire), the local plan, paragraph 5.52 justifies removing BA1 from the Green Belt on the basis that it can contribute to meeting housing requirements in the first five years following adoption of the plan. This is contradicted in the Local Plan itself as the site will only be developed after the smaller sites across the town. This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. NPPF paragraph 82 states: The general extent of Green Belts across the country is already established. New Green Belts should only be established in exceptional circumstances, for example when planning for larger scale development such as new settlements or major urban extensions. I do not believe that this is an exceptional circumstance. The BA1 North Baldock housing site has been designated purely on the basis that it is land currently owned by Hertfordshire County Council and therefore cheaply and easily acquired. There is no evidence to show that other sites were considered, and there is no assessment to show that this is the most suitable site for a development of this size. No other consideration has been given to justifying why the site north of Baldock is the best one available. Furthermore, the planned development at Baldock is vastly disproportionate to that which is planned for Letchworth and Hitchin, which are both significantly larger towns. Other land owners are prepared to put their land forward for development, however they have not been considered.

I wish to object to the North Hertfordshire Local Plan 2011-2031 for the reasons I have stated above. I do not consider it a sound plan for the future of Baldock..

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I am aware that we need to send comments and facts and reference the plan but I want to send this photo taken this morning just to show the rolling farm lands that is proposed to house 2,800 houses. This rural setting will be destroyed. The very reason people want to move to and live in the country is to get out of the rat race and traffic jams.

Building 2,800 houses on this designated land will not sustain Baldock and Bygrave's rural setting and will not enhance the town in anyway. You will find it hard to find people in favour of this proposed plan apart from the developers themselves. The council might make money by selling off the land but how much will it cost the council in the long run to maintain the roads, schools, sewerage etc. and what about the closest hospital - how will Lister Hospital (Stevenage) cope with all the extra people in the district. Are there plans for an extra hospital in North Herts?

The proposed Link Road is suppose to mitigate traffic out of Baldock but the fact remains that the rail station is at the heart of the congested junction and new residents will certainly not use the link road if they need to get the train or go to town. The Link Road is only good in mitigating traffic OUT of Baldock - how is this an enhancement to the town?

Please consider options to build South of Baldock which is closer to the A1M and the A505 and less traffic needing to use the Congested Junction coming from the North. More importantly does not require a Link Road and a bridge over a railway.

Please also consider why a town needs to be increased by 80%, surely a 20-30% increase is more reasonable and attainable. Keep Baldock rural.

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