Local Plan 2011-2031 Proposed Submission Draft

This policy is too theoretical and has not been evaluated it against what might be practicable. It relies too much on encouraging alternative modes of transport and does not adequately tackle the massive increase in motor car use that housing development will bring.

The policy requires the Council to work with service providers to provide sustainable transport options (clause c). If this has been happening, it has been unsuccessful. Recently there have been cuts in already limited bus services to Baldock. There is also a proposal to reduce the rail service at Baldock.

This policy expresses good intentions but clause b is weak. New infrastructure must always be operational no later than the completion of the new development it supports.

The admission in clause 4.75 that while a small development might not itself have a major impact, cumulatively a number of developments can create additional demands on existing infrastructure which may require suitable mitigation needs to be implemented explicitly throughout the Local Plan. This will be the case for developments on sites BA2, BA3, BA4 and BA5 in Baldock.

The Strategic Housing Sites, particularly Site BA1, have not been properly considered against all reasonable alternatives (or if they have there is no evidence for it) and have therefore not been shown to be a part of the most appropriate strategy. NHDC appears to have been entirely reactive, considering only sites put forward by landowners, instead of proactively considering all feasible sites and approaching landowners where appropriate.

The largest site, BA1, was not in the Housing Options documents of February 2013. It was first proposed (covering an even larger area) in the Housing Additional Location Options document dated July 2013, leaving relatively little time to evaluate it adequately. Baldock is the smallest of the four towns in the District, with a historic centre on a medieval street layout within a conservation area. With the proposed developments on Site BA1 and the other development sites around the town it will have by far the largest number of new homes, increasing the size of the town by a massive 73% with inevitable and severe negative effects. Road traffic is a constant problem because major traffic routes run through the central conservation area and there is very little scope for providing alternative routes. The nature of the town centre precludes enlarging retail and other infrastructure provision within the central area.

If reasonable alternatives had been properly considered there is a strong probability that site BA1 would have been at least significantly reduced in size, thereby reducing the stress on the town. The following examples, which are not necessarily exhaustive, indicate possible alternative sites. By not using the most sustainable locations the plan fails to meet strategic objective ENV1.

Letchworth Garden City Heritage Foundation has - entirely properly - considered the needs of Letchworth and offered a strategic site, LG1, for 900 homes, However, NHDC does not appear to have considered whether, looking at the needs of the District as a whole, it would have been appropriate ask the Heritage Foundation to make more land available.

The Housing Options February 2013 document included a large strategic site south-west of Hitchin, much of which was owned by a developer who also had options agreed with other landowners, sufficient for between 6000 and 7400 homes. It then disappeared from the Local Plan. The reason may be found in the Housing and Green Belt Background Paper, para. 3.14, that former site 209e, Priory Fields, was excluded because 'There was insufficient certainty that a scheme could be realised here without triggering an objection on air quality grounds.' The Local Plan notes similar air quality problems in the Hitchin Street/Whitehorse Street area of Baldock and these will be exacerbated by development on site BA1, but this site was added to the Local Plan regardless of this problem. Full development of the Hitchin Site would be excessive but using part of it could reduce the pressure on Baldock without having such a large effect on Hitchin.

There is land to the west of Stevenage which it is proposed to safeguard for future development for up to 3100 homes, which could be allocated to meet housing needs now without the adverse impacts associated with site BA1, and which has the advantage of being closer to main centres of employment, retail facilities, and public transport.

Also in the Housing Options February 2013 document there were three sites numbered 15, 014 and 012 to the south of Baldock, together estimated to be sufficient for 468 homes. Site 15 'failed one of the tests' for unspecified reasons, and the other two were rated 'priority 3', with no reasons given. These have disappeared from the 2016 Local Plan document. Although it would not reduce the total number of new homes for Baldock, if some or all of these sites were to be included it would allow a reduction in the number of homes on site BA1, which would have specific advantages, especially for transport. Being to the south of the town, these sites have easy access to the one large supermarket serving the town, at the south end of the High Street. They allow direct access to the south via London Road, to Letchworth and the west via London Road and Letchworth Gate, and to the eastern side of Letchworth (including the retail trading estate on Baldock Road) via Weston Way and the A656. All these routes avoid the congested and historic town centre conservation area.

Identify other potential housing sites, both strategic an non-strategic, and systematically evaluate these and existing sites, initially without considering availability, then open discussions with landowners of suitable sites not previously put forward. The objective should be a more proportionate distribution of planned housing among the four towns that would eliminate or at least reduce the size of Site BA1 and reduce the excessive stress on Baldock.

The Local Plan and supporting documents show that Site BA1 will have many adverse impacts which have not been given adequate weight, especially as there may be alternative sites which do not suffer such impacts. (See objections to policy SP8 Housing.)

1 Development on Site BA1 will be very difficult to integrate properly with the rest of Baldock because the railway line is a physical barrier with few crossing points. In effect, the development of Site BA1, with the infrastructure that it must have, will create a separate settlement. Thus it contravenes paras. 4.100 to 4.103 of the Local Plan, it fails to conform to the vision articulated in para. 3.6 and it fails to maintain the existing settlement pattern as required by objective ENV1.

2. The scale of growth proposed for Baldock, most of it in site BA1, will have overwhelming negative effects on road traffic in and around Baldock, but these have not been assessed adequately in the Local Plan and the proposed mitigation measures are minimal and unlikely to be effective. The draft AECOM Local Transport Modelling Report of July this year only examines the existing situation, not the impact of proposed developments, and the one mitigation measure proposed for Baldock (a mini roundabout and signal optimisation at Whitehorse Street/Royston Road) is trivial.

The proposed link road between the A507 and A505, and the proposed southern link road between Wallington Road and Royston Road B656 (in the proposals for Sites BA3 and BA4), will divert some traffic away from the junction at Whitehorse Street/Royston Road which is a known problem (para. 13.29), but additional local traffic from Site BA1 and other Baldock development sites will nevertheless lead to a large net increase in traffic through this junction. NHDC implicitly accepts that a proportion of traffic from Site BA1 will pass through this junction (para. 4.179). A high proportion of trips from Site BA1 will be towards Hitchin and Letchworth both for work and other purposes (e.g. to the retail trading site east of Letchworth) and most of these will go via this junction and through the town centre conservation area. The Local Plan notes how interconnected these towns are (paras. 2.31, 4.27, 13.14) and that many residents will commute out (paras 4.25 and 4.26). Use of the link road to the A505 to go from from Site BA1 to Letchworth and Hitchin will involve a long round trip, and most residents will not do this. In any case this route includes another problem junction, at Letchworth Gate. Trips from Site BA1 to the large supermarket at the south end of Baldock High Street will add to traffic problems within the town.

Some mitigation of the traffic problems might be achieved by upgrading an alternative route through Baldock via Icknield Way and Norton Road, but this is also very difficult and highly contentious.

The deliverability and financial viability of the link road to the A505 is questionable, given the lack of detail especially about the new rail crossing that is required and especially if, as is likely, this has to be under the railway.

The increased traffic through Baldock will breach air quality standards, which the plan notes are already close to being exceeded (para. 9.28).

3. The site makes a significant contribution to the Green Belt (Housing and Green Belt Background Paper, para. 3.14). Using it, along with the other sites around the edge of Baldock, will negatively affect the character of the landscape and townscape. The land north of Bygrave Road is of particular concern because it has been assessed as having moderate to high landscape sensitivity (Land North of Baldock: Landscape Sensitivity Study, July 2013, para. 5.2).

4. 4. There is insufficient detail about the masterplan and the other site-specific requirements that will have to be met. The list of requirements is encouraging but more detail is needed about such matters as the location of infrastructure facilities and the timing of their provision, so that they are determined before developers start producing proposals.

Part of the infrastructure needed within site BA1 is additional car parking for the railway station, and land needs to be reserved for this as close as possible to the station. This is not mentioned.

Some of the statements about infrastructure, particularly paragraphs 13.24 and 13.28, are worrying and need clarification. Development will of course occur sequentially, but any resources released by this process, be they developer contributions or community infrastructure levies, must be used first to satisfy the infrastructure needs generated by the early developments at the time those developments take place, and any funds left after that made available for upfront costs of the large strategic development. It is not appropriate for the south of the town to suffer temporary arrangements, which are all too likely to become permanent especially if costs rise, in order to fund the large development.

Schools are of particular concern. Permanent primary school places should be provided in the south of the town when they are needed, and not be delayed in order to release resources for upfront costs of the strategic development. Further expansion of Knights Templar School is problematic: it has been extended many times already. Short- to medium-term secondary provision - a temporary school - to the south of the town risks providing an inferior education unless it is as well resourced as a permanent new school, in which case it will not save money.

A major issue, if not the major issue, for the older part of Baldock is the traffic movement within and through the town centre, given that it is a conservation area and that all main routes pass directly through it. The Local Plan does not pay sufficient attention to this, and to how the pressure on the town can be alleviated.

In managing transport the Local Plan indicates that the main priority is to influence car use by promoting alternative modes of transport (paragraph 7.13). This is a worthy sentiment but there is no indication of how it is going to be achieved for the development on Site BA1. Recent experience is not encouraging: bus services to and from Baldock have got worse recently, and there is a threat that the semi-fast trains will no longer stop at Baldock from 2018. The Infrastructure Delivery Plan notes that 47% of journeys to work are in cars as drivers (paragraph 5.8). The proportion for other journeys is likely to be similar. There is no reason to suppose it will be significantly smaller in the new development. This reinforces the argument for more serious planning for motor vehicle traffic.

The particular traffic pressures that will be generated by homes on site BA1 have been discussed in detail in the response to Strategic Policy SP1.

Road access to the Sites BA2, BA3 and BA4 will be via Wallington Road, which will also carry some traffic to and from Site BA1 and to and from the Royston Road, B656. Road access to site BA5 will be via Clothall Road. Both roads converge on the roundabout at the junction of Clothall Road and South Road, and much of the traffic will use South Road to go south via London Road or to turn into the High Street. Much more thought needs to be given to managing the congestion this will create, especially because South Road is built up on both sides, is used for on-street residential parking, and is likely to suffer excessive noise (already highlighted prior to a recent adjacent development, Convent Close) and poor air quality. Thought should also be given to encouraging the use of Mansfield Road and Weston Road as a way of diverting traffic towards Letchworth from these sites away from the most sensitive part of the High Street in the conservation area.

There is no mention of parking in the town for people using its retail facilities. Parking is already barely adequate, and will be totally inadequate long before all the projected new houses are built. The difficulty of seeing a solution to this problem is no reason for ignoring it.

This is a copy of the representations about policy SP14, relating to Strategic Site BA1.

The Local Plan and supporting documents show that Site BA1 will have many adverse impacts which have not been given adequate weight, especially as there may be alternative sites which do not suffer such impacts. (See objections to policy SP8 Housing.)

1 Development on Site BA1 will be very difficult to integrate properly with the rest of Baldock because the railway line is a physical barrier with few crossing points. In effect, the development of Site BA1, with the infrastructure that it must have, will create a separate settlement. Thus it contravenes paras. 4.100 to 4.103 of the Local Plan, it fails to conform to the vision articulated in para. 3.6 and it fails to maintain the existing settlement pattern as required by objective ENV1.

2. The scale of growth proposed for Baldock, most of it in site BA1, will have overwhelming negative effects on road traffic in and around Baldock, but these have not been assessed adequately in the Local Plan and the proposed mitigation measures are minimal and unlikely to be effective. The draft AECOM Local Transport Modelling Report of July this year only examines the existing situation, not the impact of proposed developments, and the one mitigation measure proposed for Baldock (a mini roundabout and signal optimisation at Whitehorse Street/Royston Road) is trivial.

The proposed link road between the A507 and A505, and the proposed southern link road between Wallington Road and Royston Road B656 (in the proposals for Sites BA3 and BA4), will divert some traffic away from the junction at Whitehorse Street/Royston Road which is a known problem (para. 13.29), but additional local traffic from Site BA1 and other Baldock development sites will nevertheless lead to a large net increase in traffic through this junction. NHDC implicitly accepts that a proportion of traffic from Site BA1 will pass through this junction (para. 4.179). A high proportion of trips from Site BA1 will be towards Hitchin and Letchworth both for work and other purposes (e.g. to the retail trading site east of Letchworth) and most of these will go via this junction and through the town centre conservation area. The Local Plan notes how interconnected these towns are (paras. 2.31, 4.27, 13.14) and that many residents will commute out (paras 4.25 and 4.26). Use of the link road to the A505 to go from from Site BA1 to Letchworth and Hitchin will involve a long round trip, and most residents will not do this. In any case this route includes another problem junction, at Letchworth Gate. Trips from Site BA1 to the large supermarket at the south end of Baldock High Street will add to traffic problems within the town.

Some mitigation of the traffic problems might be achieved by upgrading an alternative route through Baldock via Icknield Way and Norton Road, but this is also very difficult and highly contentious.

The deliverability and financial viability of the link road to the A505 is questionable, given the lack of detail especially about the new rail crossing that is required and especially if, as is likely, this has to be under the railway.

The increased traffic through Baldock will breach air quality standards, which the plan notes are already close to being exceeded (para. 9.28).

3. The site makes a significant contribution to the Green Belt (Housing and Green Belt Background Paper, para. 3.14). Using it, along with the other sites around the edge of Baldock, will negatively affect the character of the landscape and townscape. The land north of Bygrave Road is of particular concern because it has been assessed as having moderate to high landscape sensitivity (Land North of Baldock: Landscape Sensitivity Study, July 2013, para. 5.2).

4. 4. There is insufficient detail about the masterplan and the other site-specific requirements that will have to be met. The list of requirements is encouraging but more detail is needed about such matters as the location of infrastructure facilities and the timing of their provision, so that they are determined before developers start producing proposals.

Part of the infrastructure needed within site BA1 is additional car parking for the railway station, and land needs to be reserved for this as close as possible to the station. This is not mentioned.

This site needs a link to Clothall Road, A507. This is not stated.

Development of Site BA2 would not by itself to justify additional infrastructure, but the total number of homes proposed for Sites BA2, BA3, BA4 and BA5 exceeds the threshold for a strategic housing site (para. 1.3 of the Local Plan) and requires appropriate additional infrastructure. This is not made sufficiently explicit. Existing infrastructure (schools, health care etc.) operates close to capacity, so the additional infrastructure needs to be provided at an early stage (most likely within enlarged Clothall Common estate).

Development of Site BA3 would not by itself to justify additional infrastructure, but the total number of homes proposed for Sites BA2, BA3, BA4 and BA5 exceeds the threshold for a strategic housing site (para. 1.3 of the Local Plan) and requires appropriate additional infrastructure. This is not made sufficiently explicit. Existing infrastructure (schools, health care etc.) operates close to capacity, so the additional infrastructure needs to be provided at an early stage. Given that the existing Clothall Common development has little infrastructure the new provision should be situated within the enlarged Clothall Common area.

Development of Site BA4 would not by itself to justify additional infrastructure, but the total number of homes proposed for Sites BA2, BA3, BA4 and BA5 exceeds the threshold for a strategic housing site (para. 1.3 of the Local Plan) and requires appropriate additional infrastructure. This is not made sufficiently explicit. Existing infrastructure (schools, health care etc.) operates close to capacity, so the additional infrastructure needs to be provided at an early stage. Given that the existing Clothall Common development has little infrastructure the new provision should be situated within the enlarged Clothall Common area.

The proposals fail to consider the possibility of providing additional vehicle access to Hartsfield School by suitably managing the development of this site. In principle all the Clothall Common Estate may be within walking distance of the school but in reality many children are driven to the school (often for compelling reasons), and there is no point in denying this. Driving to the main school entrance on Clothall Road causes additional congestion that could be avoided if there was vehicle access within the estate.