Section One - Introduction and Context

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

Site AS1 fails to meet the requirements for Highway safety to protect pedestrians and other road users as defined in both National Planning Policy framework and NHDC's own current and emerging Planning policy for highway safety
It also does not meet requirements to protect valued landscapes under the NPPF
It does not the requirement to protect the Historic environment and is protected by NPPF and NHDC policy Sp13. para 4.151 of the document
There has been no consultation to extend the settlement boundary in locations other than AS1 by NHDC.

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

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

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

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

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

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

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

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

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

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Policy SP5 Countryside and the Green Belt
Policy SPG15 Site LG1 North of Letchworth Garden City
Paragraph 13.215 LG3 Land East of Kristiansand Way and Talbot Way
Where a large areas of existing Metropolitan Green Belt North and East of Letchworth has been re-designated as residential development land and proposals for the use of these sites (LG1 and LG3) for housing development.
These policies are not Legally Compliant as the Sustainability Assessment does not form a suitable assessment of the sustainability of the council's proposals. The SA does not consider the undesignated heritage asset status of the Green Belt which was an integral part of the design of Letchworth, and the first designed Green Belt in England. The Green Belt is an important factor in the setting of the Heritage Asset which is the town of Letchworth.
These policies are not Sound as:
a) They are not positively prepared as they are not consistent with achieving sustainable development as set out in NPPF. 7 pg 2
"There are three dimensions to sustainable development: economic, social and environmental. These dimensions give rise to the need for the planning system to perform a number of roles:"

"an environmental role- contributing to protecting and enhancing our natural, built and historic environment;......"
They are not justified or consistent with national policy as they do not comply with the following sections of NPPF:
a) 9 Protecting Green Belt Land
79 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.
80 The Green Belt serves five purposes:
to check the unrestricted sprawl of large built up areas
to prevent neighbouring towns merging into one another
to assist in safeguarding the countryside from encroachment
to preserve the setting and special character of historic towns
to assist in urban regeneration, by encouraging the recycling of derelict and other urban land."
The proposals in SP5, SP15 and para 13.215, to re-designate the Green Belt land north of Letchworth, do not recognise or conform to all of the above five purposes.
83"...Once established Green Belt boundaries should only be altered in exceptional circumstances..."
MP Brandon Lewis confirmed in his letter to Boris Johnson of January 2015, that the need to meet Housing Targets did not constitute exceptional circumstances.
"NPPF is clear that Green Belt should be given the highest protection in the planning system and is an environmental constraint which may impact on the ability of authorities to meet their housing need. This Department published guidance on 6 October 2014 which re-affirms that Green Belt boundaries should only be altered in exceptional cases, through the preparation or review of the Local Plan. The guidance also states that the housing need alone does not justify the harm done to Green Belt by inappropriate development when drawing up a Local Plan."
The exceptional circumstances have not been demonstrated and reasonable alternatives to the use of sites LG1 and LG3 have not been identified, described and evaluated before the choice was made. The sites included in the appraisal were only those which owners put forward and the Draft Sustainability Appraisal document sets out in para 5.2.1 that to be considered a site had to be available for development. No alternative sites which would not cause such harm to the significance of Letchworth and its Green Belt were sought.
b) 11 Conserving and enhancing the natural environment

109 " The planning system should contribute to and enhance the natural and local environment."
110 "...Plans should allocate land with the least environmental or amenity value, where consistent with other policies in this framework."
The Green Belt Review Study, sets out a scoring process for the sites put forward by owners which aims to establish which sites make the most significant contribution to the Green Belt. This system is flawed in the following ways and therefore not justified or consistent with national policy:
a) It says on page 30, para 44. "Letchworth Garden City has a relatively strong relationship with the surrounding countryside, particularly to the south where there is a clearer connection to the original footprint of the town."
This statement is not justified, the "original footprint of the town" quoted is simply the first area developed, from Norton Road in the north to Baldock/Hitchin Road in the south. This was by no means the intended size of the Garden City, Howard designed it to have 32,000 residents, that number has only recently been achieved with the addition of the Grange, Jackmans, Lordship, Manor and Westbury Estates. The town's relationship with the surrounding countryside is equally as strong in the north as in the south.
The following quote from Ebenezer Howard's book, Garden Cities of Tomorrow 1902 is relevant:
"Garden City has, we will suppose, grown until it has reached 32,000. How shall it grow? How shall it provide for the needs of others who will be attracted by its numerous advantages? Shall it build on the zone of agricultural land which is around it and thus forever destroy its right to be called a "Garden City"? Surely not. This disastrous result would indeed take place if the land around the town were, as is the land around our present cities, owned by private individuals anxious to make a profit out of it. For then as the town filled up, the agricultural land would become ripe for building purposes, and the beauty and healthfulness of the town would be quickly destroyed. But the land around Garden City is, fortunately not in the hands of private individuals: it is in the hands of the people: and is to be administered not in the supposed interests of the few, but in the real interests of the whole community."
b) Page 25, Parcel 22, under heading "Preserve setting and special character of historic towns"
"Forms part of countryside between Letchworth and Stotfold in Beds. Performs a more limited function due to landform resulting in limited views of any historic towns".
This analysis is far too simple, the historic town of Letchworth, the world's first garden city, and its integral Green Belt is completely ignored. The built up boundaries of Letchworth are clearly visible and its surviving Green Belt still performs its original design function to allow residents access to the countryside and for the grade 2 agricultural land to be farmed, and to provide the countryside setting for the Garden City as envisaged by Howard.

c) Page 117 section 5.3. Assessment of Potential Development Sites Land East of Talbot Way, and Land North of Croft Lane.
These sites adjoin Norton Conservation Area and Norton should be assessed as a village whose built boundaries should not be extended (in the same way that Willian the village to the South of the town, has been assessed). The statement in the Local Plan 2011-2031 page 181 para 13.209, that Willian has not been absorbed into the Garden City whilst Norton has, is not correct, Norton retains 3 sides of the village in contact with the countryside and it is only the houses on the East side of Norton Road which link it to the Garden City. Willian has a similar link along Willian Road from Letchworth Gate.
d) Page 118 North Letchworth
We do not consider the assessment to be accurate, this potential development site has 3 sides (North, East and West) which do not have development adjacent, if this had been used for analysis, rather than how many sides have development adjacent, then this site would have scored more highly. The wildly different shape of sites means that this method of assessment is not accurate.
There is no mention in the NHDC Local Plan or any background documents, of the proposed 22.5 hectares of residential sites to the East of Hitchin Road, in Central Beds Draft Local Plan, (work has already started on some of the houses). These proposals will bring the proposed development of North Letchworth closer than 500m to this Central Beds development, which as an extension of the Fairfield development will almost link Letchworth and Fairfield. The effect on the Green Belt has not been taken into account and this should result in a higher score under Towns Merging heading. The proposed development would also reduce the Green Belt between Letchworth and Stotfold to 500m in places. It is evident that the development of this North Letchworth site would result in the unrestricted sprawl that Green Belt designation is designed to prevent. The issue of co-operation on strategic and cross-boundary issues is relevant here.
Under the heading of "Preserve setting of historic town" this analysis says "site not within or affecting setting of a conservation area of a historic town". This is not a correct assessment of the importance of Letchworth's Green Belt as an integral part of the town's design and an important factor in its setting. The significance of the historic town of Letchworth, the world's first Garden City, would be seriously harmed by the loss of this area of Green Belt. A higher score should have been given here.
There is no Heritage Assessment Document for Letchworth prepared as part of the Background Papers, although Baldock Hitchin etc. have such assessments. A well informed Heritage Assessment for Letchworth would have identified the special historic character and significance of the World's First Garden City and its Green Belt, the first designed Green Belt in England.

Whilst Letchworth has its designated heritage assets in the form of listed buildings and Conservation Areas, it is also of local heritage importance in its entirety, as designed, with its Green Belt. This has not been considered in this Local Plan exercise.

Policy SP17 Site HT1 Highover Farm Hitchin
This policy is not Sound as it is not consistent with national policy.
NPPF says that green belt should only be altered in exceptional circumstances. Here the green belt between Hitchin and Letchworth will be reduced to 500m if this development goes ahead. No exceptional circumstances have been demonstrated.
The development will result in the unrestricted sprawl that the green belt is designed to prevent.

The modifications we would like to see are the removal of LG1, LG3 and HT1 from the list of proposed development sites and an exercise to identify sites to provide the housing needed in locations which do not harm the significance of Letchworth Garden City and its Green Belt.

We would like to participate at the oral part of the examination.

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