Local Plan 2011-2031 Proposed Submission Draft

This is based on an assumption that existing towns have spare capacity within their facilities and infrastructure, but this is incorrect. In Baldock for example the schools are already over subscribed, the road network is at capacity with no options for expansion (due to pinch points at historic junctions and narrow roads bounded by listed buildings hundreds of years old, and the situation of the railway line and the narrow rail bridge allowing traffic under it), the GP surgery is at capacity, and leisure and sporting facilities are also at capacity (in fact Baldock has far below the recommended level of open space and sporting recreational area/facilities). Furthermore, it assumes that development of existing towns will help to meet local housing need - however, since the biggest site (north of Baldock, Blackhorse Farm) lies in what used to be greenbelt (until it was removed as part of the review which forms part of this Local Plan) and is situated right next to the train station with a fast connection to London (34 minutes to London Kings Cross) then development of this site will in fact lead to massive upward pressure on house prices in that development (within 20 minutes walk of the station) and a consequent uplift in prices in North Hertfordshire. In short, a very large number of houses in this plan will go toward inward migration of people currently living in London who wish to continue working in London - this will leave housing need left unmet and also drive up prices, in fact exacerbating problems in North Hertfordshire. This would be easily mitigated by scaling back the development north of Baldock and separating it from Baldock by a strip of Greenbelt (or developing this strip only at the end of the period).
Also, the council needs to accelerate efforts to establish new towns (garden villages) within the district. Although little work has been done so far, and so these cannot contribute to the figures in this plan, it should be the aim of the plan to establish 2 new garden villages in the district by the end of the period (for example at Odsey which is further along the train line and less desirable for commuting to London, and at a location half way between Luton and Stevenage, which would not be on a current train line, but would offer short commutes to the local towns) - depending upon how these new settlements progress, then the Plan will have flexibility to alter plans elsewhere as the plan is reviewed over the period.

Although the text claims that the Plan seeks to allow villages to grow as vibrant functioning communities, it looks like it will actually act to stifle growth in the villages of all sizes. The green belt review, which forms part of this Local Plan, whilst removing large areas of green belt around existing towns intends to smother the whole of the south of the district in greenbelt - this is quite unnecessary the existing green belt areas provide sufficient protection against the encroachment of the existing large settlements of Luton, Stevenage and London. Plan seems to indicate that in the villages only infill or development within existing village boundaries will even we considered - this actively works to limit options for development and will stifle development, drive up house prices and kill these villages and functioning communities. The plan needs to be clearer about the circumstances under which development outside village boundaries will be considered. The villages should not be allowed to die under a misplaced desire to leave them untouched by modern development.

Developing close to Baldock train station with its fast link to London as a result of releasing Green Belt land will only serve London housing need and will leave local housing need unmet, whilst also driving up house prices and placing Baldock facilities and infrastructure under additional strain, when they are already over stretched and unprepared for extra load.
The plan should include the establishment of 2 new garden villages that will in time grow into garden towns (even if building of them is barely begun by the end of the period).
Plan seems to actively stifle development of villages of all sizes (whist the text states it aims to do the opposite), by restricting options for development too much.

I support the creation of additional space for business by the railway line in the east of Baldock. This is sensible - it will create employment opportunities in the local area and may help to reduce a small part of the additional through traffic that will be caused by so much housing development to the east of Baldock (when all other areas of employment lie to the west of Baldock and the district). Such development should be of the B1 categories described, due to the limited road access, the rural setting and the proximity to the new housing developments, and due to the size and shape of the area (large industrial or warehouses would not fit well and so be unlikely to be developed).

I support the creation of a new town centre in the new development to the north of Baldock - this should include leisure facilities and green space.

With the additional development around Clothall Common, a single local shop will be supporting a large neighbourhood of dwellings. Either the cluster of developments around Clothall Common nearly 600 additional homes should have a strategic plan/masterplan, which could consider options such a new local shop or community facilities such a hall or leisure facilities - or it should be specifically mentioned in this plan.

4.53 The 'exceptional circumstances' that North Hertfordshire District Council find itself in such that it needs to remove Green Belt protection from large areas of prime arable land, with a significant impact on the local setting and countryside is entirely self manufactured. By refusing to do any planning whatsoever for new settlements in North Hertfordshire it has created a manufactured urgency where the district is left without a Local Plan or a 5 year land use plan and councillors and residents are forced to accept a plan that many consider flawed. This sets a terrible precedent nationally for other district councils to follow whereby difficult decisions about reusing industrial land, creating new settlements or increasing density within larger settlements can be kicked down the road and large areas of easy to develop Green Belt can be rezoned under the 'exceptional circumstance' of local housing need. For this reason alone this rezoning should be objected to and scaled back. However, it is also ambitious and highly risky for a district council with low competency maturity for delivering large developments in partnership with commercial developers (for example the Church Gate development in Hitchin or the chaotic development of Great Ashby) to assume simply rezoning a large area and leaving it to developers will result in an effective plan. Whereas other options such as creating new settlements and/or spreading the development out more evenly with more nuanced changes to the Green Belt seem much less risky, easier for the district and county council to deliver and much more realistic. Furthermore, the Plan assumes that the particular area north of Baldock will result in large amounts of affordable housing, but ignores that its previous Green Belt status has prevented an area very close to a train station with a fast (34 minutes) link to central London from being developed in the past and that releasing it will simply create a pool of extremely high value housing that will not meet local housing need and may in fact drive up house prices in the area - they haven't fully considered what rezoning a large area of green belt means and what the implications of such as action might be - in other words they have not thought it through. But this can be mitigated by scaling down the development, separating it from Baldock and the train station (and preferably from Bygrave also), and then looking to make up the short fall in other areas of the district (perhaps by looking at areas considered in previous iterations of this plan) and by a commitment to establish (zone and build the first homes of) 2 new settlements in the district within the plan period (not in the next plan period, when the district council planners can once again kick the can down the road and manufacture the urgency requiring yet more large scale growth around one of the existing towns).

4.55 the assertion that Green Belt releases can be offset by additional Green Belt elsewhere is frankly ridiculous. What is more there is absolutely no need to cover the whole of the south of the district with Green Belt, stifling growth of villages and cutting off options for new settlements in the area - the existing Green Belt zones are sufficient - they have done their job until now and there is no evidence that they need to be strengthened. Encroachment from London, Stevenage and Luton as been sufficiently curtailed by the existing zones and they should be left largely unchanged.

The blanketing of the southern half of North Hertfordshire in Green Belt is unnecessary and counter productive. Where Green Belt has been released for development there are a number of additional policies which should be put in place to enhance the rural character of these communities and to encourage participation with the countryside.

Finally, it is important that there is sufficient tree planting in the development of newly release Green Belt, which will start as bare farmland.

This Local Plan includes a mass redrawing of the Green Belt in North Hertfordshire (although separated out into a separate document). The vast majority of North Hertfordshire (outside of its main towns) is undeveloped and facing challenges in terms of high property prices and under occupation. This plan covers these areas with Green Belt and creates additional developmental barriers whilst removing Green Belt protection from very large areas of highly productive and attractive land around the existing towns - particularly to the north of Letchworth and most notably all around Baldock. (It should be noted that District Council has recently been refusing development plans in villages on the grounds of impact to the country side, e.g. at Whitwell, whilst encouraging destruction of countryside around towns in this plan - this demonstrates the need for the to the plan to clearly and actively encourage rather than discourage development of the villages and hamlets of North Hertfordshire, otherwise the trend to underdevelopment, high cost of living and under-occupancy in these areas will continue.) I object strongly to the blanketing of all the the southern half of North Hertfordshire in Green Belt - the existing Green Belt zones provide sufficient protection against encroachment from Stevenage, Luton and London. It will also unnecessarily exclude (or make it more difficult to consider) these sites as possible sites for a new Garden Village - it could be seen as a cynical attempt to entrench a bias toward over development of existing towns and continued underdevelopment of other areas of the district.
Furthermore, the Green Belt review has removed Green Belt protection for very large areas around Baldock (and surrounding towns such as Ashwell) and north of Letchworth. 13.16 states the town boundary as being that shown on the proposal maps, but this is the boundary after the Green Belt review, which I understand forms part of this Local Plan. The sites BA1 and BA3 were previously greenbelt and this status has clearly been removed in order to facilitate development. It would be of considerable benefit to the areas adjacent to the sites (both developed and non-developed/farming) if their recent greenbelt status was recognised in the plan and additional policies put in place. It represents a significant unbanisation of these adjacent areas, particularly Clothall Common, which is currently bounded on 3 sides with open farmland, but instead will become bounded on 3 sides with urban areas - without mitigation this would reduce access to the countryside, deteriorate surroundings and have a negative impact on health and well being (for example, through diminished countryside access/activities, like jogging, walking, cycle riding, dog walking, etc.) - in short, without specific policies it would make these developments unsustainable. A review of Green Belt around these areas, particularly in light of housing need in the district is to be expected - that such huge areas of protection should be removed against the wishes of the residents of North Hertfordshire as expressed in such large numbers in the responses to the Preferred Options Plan, is astonishing. However, given the housing need (and lack of other options explored by the district council creating a 'manufactured urgency') I accept that these areas will need some development - it is vital that the Local Plan accepts the recent Green Belt status of these areas and identifies them for additional policies and protections. It is entirely possible to maintain the rural feel of these recently Green Belt areas, to encourage interaction and participation with the countryside, and to limit the impact of development in these areas to the countryside, and to do so without affecting the deliverability of development at these sites, or indeed by altering the actual number of homes delivered at these sites very much. For example, 'green lanes' or strips of actual green belt could be inserted between existing boundaries and the newly released areas of development; Also housing density could be limited in these zones and additional planning requirements in terms of 'rural' character of development and consistency with local historical architectural styles could be applied to these zones; Additional requirements for open areas, playing fields and recreational spaces could be placed on these zones; And to ensure continued access and participation with the countryside, green lanes linking existing countryside access points to the new access points at the new boundary could be required, as well as requiring a review of all permanent farm tracks in the adjacent countryside with the aim of upgrading them to footpaths and bridal paths to encourage greater participation in the countryside (to be carried out before development commences to ensure it is not simply ignored by the planning and development process, assuming it would be swift and cheap to complete - a 'quick win') - this would mean that development of these areas actually enhances the rural character of the developed areas and ensures the sustainability of these sites.
Finally, from reading the document, I don't think the policies are specific enough about the need for tree planting in the newly released areas of Green Belt - arable farm land will be starting very bare and for developments (particularly around Baldock and especially around Clothall Common) to be consistent with the character of existing developments and the local townscape, significant tree planting will be required. These policies need to be strengthened, and the sites themselves should give mention of this requirement.

4.62 the Sustainability Appraisal in fact lists many negative effects of releasing Green Belt. However, in comparing two options - development around existing towns or development of new Settlements - the Sustainability Appraisal makes three flawed assumptions which have had a drastic impact on the plan.
Firstly, it assumes that development of land north of Baldock will help to meet local housing need, however, it takes no account of the fact that the land is right next to the train station which has a direct fast (34 minutes) link to central London - the impact of this is that a large strip of this development (the area within 20 minutes walk of the station) will go toward London housing need and so will be strongly affected by house prices in the London Housing Market and will leave local housing need unmet and it may well act to drive up local house prices. The reason, I think, that this has been ignored is because it has been assumed that the Stevenage Housing Market will apply to this development - but that assumption is based on normal organic growth, where existing high value locations (for example close to fast connections to London) have previously been developed - however this is not the case for this site because this land was previously protected by the Green Belt allocation. The Sustainability Appraisal has failed to consider properly the impact of releasing so much previously Green Belt land so close to the train station. As mentioned elsewhere, this omission can be mitigated by separating the new development from Baldock so that very little of it is less than 20 minutes walk of the station, or by developing this strip only when the rest of the site has been developed.
Secondly, the Sustainability Review assumes that existing facilities of existing towns can be efficiently leveraged by building onto those town, but takes no account of the fact that (in Baldock at least) existing facilities and resources are severely overstretched. For example, schools are very over subscribed, the GP surgery is a capacity, open space and leisure facilities are far below national averages and target values (from tables within Sustainability Appraisal documents themsleves) - so extending existing towns is actually starting from a deficit of local facilities and resources. However, it is clear the development creates opportunities to address this deficit and it is vital that the plan takes positive action to do so. It must recognise the poor starting point and deliberately set out to improve the overall situation as a result of any large scale development (for example the large site north of Baldock, or the cluster of sites surround Clothall Common, to the east of Baldock).
Thirdly, it assumes that the District Council and County Council have the competency maturity to develop large sites quickly. Recent experiences, (for example, Great Ashby or the Church Gate development in Hitchin) point to this not being the case, and the largest sites should be scaled back and development distributed more evenly around the district.
I also feel strongly that establishing (starting) 2 new garden villages by the end of the plan, will help create new options and facilitate an effective and achievable increase in the amount of housing and employment in the district - it will also set up options for continued sustainable development in the following planning period (rather than creating another cliff edge, like-it-or-lump situation of manufactured urgency).

Sustainability Appraisal does not consider the release of so much Green Belt close to Baldock train station (with a fast link to London) as exceptional and instead assumes Stevenage HMA house prices will apply - it will in fact encourage migration from London and there needs to be a mitigation against this. It also assumes the district and county councils can deliver large developments quickly, against recent experience. Without these flawed assumptions the option of new settlements would have risen above the option of extending existing towns, or a least a blend of both approaches.

With regard to point 4.62 there are flaw in the Sustainability Appraisal.
The sustainability assessment is comprised of multiple documents concatenated together. I have only had time to skim this document. I do not have a planning background and I apologise if my comments misuse jargon or repeat things.
> Page 89 approx., points out that BA1, BA10, BA4, BA3 and BA2 all lie in open countryside on the northern and eastern edge of Baldock. 2(b) points to a requirement to provide access to green spaces and Maintain existing rights of way. It is highlighted that the distance to open countryside from existing housing will be increased.
Policies mentioned in these documents don't seem to match up with the latest version of this plan - perhaps they relate to earlier versions? It states policy D1 will ensure through-routes are incorporated in new development, but that must be a different policy. The location of these sites to the north and east of Baldock and of all the major sites of employment and entertainment is a major flaw with these sites that hasn't been considered properly.
> Page 90 approx., states that Baldock BA1, BA10, BA4, BA3 and BA2 all lie in areas of high or moderate sensitivity. 3(b) states there will be residual landscape impact.
In seeking to develop up to 'defensible' boundaries, it is important to respect the impact on the landscape.
> Page 96 approx., reduced access to open countryside, potential negative effects on human health - highlights Baldock, Royston and Great Ashby.
Steps must be incorporated into the plan to increase access to open countryside and not simply accept this as a negative consequence of development at these sites!
> Page 103 approx., Table 35: Residual significant sustainability effects of the Plan. States reduced access to the countryside. Sites this as being of high probability.
Again, vital to take steps against this, or indeed to reverse this.
> Page 104 approx., Reduction in quality of landscape and townscape character. For Baldock (and other sites) this is sited as of high probability, permanent and irreversible.
It is vital that the character of the landscape and townscape is respected as much as possible - I believe, separating the development to the north of Baldock, from Baldock will help to preserve the townscape character and will also preserve the character of the countryside around that location (rather than converting Baldock from a small town to a large town with the consequent impact).
> Targets for England: hectares per 1000 people, playing fields 1.2, all outdoor sports 1.6, equipped/designated play areas 0.25, other outdoor provision 0.3. Targets for East of England: children's playspace 0.7, outdoor sporting space 1.7, amenity space 0.8 (from Planning Obligations Strategy 2009). Actual for Baldock: outdoor sports facilities 0.41.
This is far below the target values, far below the average for the district and only Royston is lower on the table (which has been the recipient of a lot of recent development and is not a good precedent of the likely effect of development at Baldock). It is vital that development north and east of Baldock results in new open playing fields as well as new sporting facilities (for example tennis courts or new leisure facilities, perhaps tied to a new school). For the north of Baldock site it is possible to imagine that this will be ensured by the strategic plan covering that site, however, the cluster of developments surrounding Clothall Common on the east of Baldock is not covered by a strategic plan - it should be so as to ensure proper consideration of factors like additional facilities (among many other concerns of adding so much housing at one location - even though it is in 4 sites, they are very close to each other around a single part of Baldock).
> It seems from a skim of this Sustainability Assessment that it takes loss of Green Belt into account when considering the impact of a new settlement, but then does not take it into account (certainly gives it a lower consideration) when considering the impact of a large development attached to an existing town.
This is a serious flaw in the analysis - it needs to be acknowledged and remedied as best as possible.
> The Sustainability Assessment appears to assume that house prices will go down with a large development on the edge of an existing town.
However, releasing land for development so close to Baldock train station (with a 34 minute direct link to London) may drive house prices up. This is a significant flaw in the assessment.
> (item 1 and item 5(d) of option (a) continue development of 4 main towns including development of greenbelt). Option C, item 1 and item 5(d) of option (c)
Appear to suffer the same flawed assumption that building large numbers of housing must necessarily improve affordability, without taking into account the possibility of London commuters taking advantage of newly released land close to the train station and so actually driving house prices up and reducing affordability. It is vital mitigations are put in place - for example, leaving a strip of Green Belt near the train station, or ensuring this land can only be developed when the rest of the site (and other site around Baldock) are been developed. This assumption though is correct in the case of Item 1 and item 5(d) for a new settlement, as the only sites available for new settlements will not provide attractive settlement locations for people wishing to commute to London. This option will make housing more affordable across North Hertfordshire. There is no reason that some progress on this option could not be made over the period of the plan. The expectation that sites will be identified and development will commence during the period of the plan should be included in this plan. If progress is made on this option, other aspects of the plan can be reviewed accordingly. In fact, a long list of possible sites could be included in this plan to show good faith toward pursuing this option over the period of the plan. To kick the can down the road until the next plan is to accept unaffordable housing and non-sustainable development, with the hope that new settlements might be included in the next plan - this is why I feel it is vital that this aspect is included in this plan, so we can see progress against it over the period of this plan. Such sites cannot be counted against forecasts of housing to be delivered by this plan, as such sites might not be deliverable during the time-frame of the plan, however, it is vital that progress is made against this option, and it is also possible the development could (in fact should) commence, in part, on new settlements during the period of this plan and this must not be deliberately excluded by this plan.
> page 533 approx., 5(b) of section 2.2 Baldock site BA1, fails to take into account the proximity of the train station in relation to affordability of housing.
> page 535 approx., 2(b) of section 2.2 Baldock site BA3,
I agree that the site provides the potential for new sporting or recreational spaces and at this position in relation to Baldock and the few other areas, this would likely have a big impact on health and well being of residents in Clothall Common, this new site, and this side of Baldock.
> Page 530 approx., Site BA1 mitigation tables
the proximity to the train station with a direct fast link to the centre of London is an important feature of this site and mitigation should be put in place to ensure new housing doesn't simply contribute toward inward migration of people currently living in London and who will continue to work in London (a long and environmentally friendly journey). For example that the land nearest the train station be given a special status, be developed last of other such mitigation.
> Section 1 - HMA housing market areas,
fails to take any account of 'commuter belt' - areas that receive an uplift due to an easy commute into London and the higher salaries that can be obtained there. This is because it assumes organic growth, where locations close to good transport links into London tend to already be occupied and growth will be via in-fill (as has occurred in the centre of Baldock). However, the massive site to the north of Baldock (BA1, Blackhorse farm) is exceptional as it lies very close to the train station and has been left undeveloped due to it's prior greenbelt status which has been removed as part of the review which forms part of this plan. The plan makes no accommodation for the exceptional nature of this site, situated so close to a train station with a fast (34 minutes) link directly into central London (London Kings Cross). It assumes that the normal HMA will apply to these houses, whereas, the strip of this development within a 20 minute walk will not fall into the normal rules of the Stevenage HMA but will instead be influenced by a significant uplift due to inward migration of people currently living in London (who are influenced by a very different and much more expensive HMA in London) and who will continue to work in London, leading to a large uplift on these houses. This seems obvious, so it is extra ordinary that this has not been considered as part of the plan. It is vital that this is considered. Easy mitigations, such as leaving the area closest to the train station undeveloped, or developing this strip last will greatly affect how effective this plan is at meeting local housing need in a deliverable and sustainable manner.

SP6 point g and paragraph 4.72 should be strengthened - with the loss of so much Green Belt and with detrimental effects on access to the countryside having been highlighted by the Sustainability Assessment, then point g should commit to the review and creation of new rights of way (footpaths and bridleways) to encourage greater access to and participation with the countryside. This will have a positive effect on health and well-being and will also be a demonstrable benefit from development in the plan - i.e. it will help make the plan more sustainable, in the short and the long term.

4.88 The Plan concludes that sensible expansion of towns and villages is the best way of delivering growth needed, whilst protecting the rural character of the District - however, the massive development to the north of Baldock is not a sensible expansion, it is too large and too fast for the district and county councils to manage and will destroy the rural character of that area and Baldock as a whole. Furthermore, the conclusion that expansion of existing towns is the best option is based on a Sustainability Assessment which is flawed in a number of ways. Firstly it assumes that homes delivered by town expansion would be covered by the local housing market which is the Stevenage HMA, however, the massive site north of Baldock is land, being released from Green Belt, that is very close to the train station with a direct fast (34 minutes) link to central London - any part of this development within 20 minutes walk of the station will be affected by London house prices and more over will go to meet London housing need and not to meet North Hertfordshire housing need. This is easily mitigated by maintaining a strip of Green Belt between the new development and Baldock, or by developing this strip only when the rest of the site has been developed. Secondly the Sustainability Review appears to make no regard for how overstretched existing facilities and infrastructure are in the existing towns and whether they can in fact be sustainably increased as part of expansion of the town - in Baldock for example the road layout with narrow roads at pinch points and the position of listed buildings hundred of years old along key roads and junctions, makes it almost impossible for it to accommodate much increase in traffic, but this has not been considered. Finally, it makes no regard for whether several small extensions are as achievable as a single large one - I believe, based on recent experiences at Great Ashby and the Church Gate fiasco that the district and county council may have the ambitions but do not have the capability to deliver single large developments, and that smaller, more evenly spread developments would be more achievable. Furthermore, the plan as it currently stands appears to stifle development of villages of all sizes (by restricting development and trying to cover large new areas with Green Belt needlessly).

Re: Point 4.90 There are several sites that surround Clothall Common on the east of Baldock. Although they are separate sites, they are almost adjacent and are all adjacent to Clothall Common. The total number of homes delivered by these sites is greater than the 500 level set in this plan as the requirement for a strategic plan, and given the dramatic effect these sites will have on Clothall Common and that they are all planned to be developed first and rapidly in order to facilitate the development to the north of Baldock, then these sites should be covered by their own strategic plan. It seems that a lot of the initial conversations about schools and roads have already happened in regard of these sites (from comments made by councillors at information meetings), so creating a strategic plan would not delay implementation, but would ensure that effects and benefits of the sites are considered in combination - for example, do they create a need for more open space, playing fields, sporting facilities, leisure facilities, community facilities, local shops, bus routes, tree planing, etc.
It is clear that a large part of the site (BA1) north of Baldock, within 20 minutes walk of the train station with a direct fast (34 minutes) link to central London, will go to meet London housing need and will leave North Hertfordshire housing need unmet, whilst increasing the load on local facilities and infrastructure and driving up house prices. It is also clear the the district council has failed to make progress on establishing new settlements over the existing period and I see no reason to expect that they will do so over the new period - leading to an even greater housing need at the end of the period of the Plan. The solution is ensure building of new settlements has begun (even if it is only a few homes!) by the end of the period of this plan and that this commitment is included in this plan.
4.100 should have an additional sentence. "This plan commits to the establishment of 2 new settlements, including at least the very first stages of development, that will be able to grow into Garden Villages and then Garden Towns in the future. This is the best way of creating sustainable options for development in the future."
4.101, the first sentence should be changed to The Council is committed to fully exploring settlement options in the District and to establishing at least 2 new such settlements over the period of the Plan.
4.103 is conjecture - it is correct that there are constraints, but whether additional sites can meet future need is unknown, but starting on them will certainly create new options. 4.103 should be changed to "If a new settlement is pursued, it might not meet all future need and there might still remain a need to identify additional sites".
4.109 Self-build is an excellent way to increase the plurality of delivery methods of new development in the plan. I believe that there has been a resurgence in self build across the country (based on perceptions from media reporting and from anecdotal evidence - a close friend is looking at self build as the only way to provide his family with an affordable home). Self build also provides affordable housing and tight knit communities, with varied, interesting and characteristic housing stock. The target for self build should be increased, 1 % is too low.
A another strategic housing site or masterplan requirement should be added, comprising the sites surrounding Clothall Common on the east of Baldock - almost adjacent to each other and dramatically affecting Clothall Common. Together these sites deliver well over the 500 homes minimum that the Plan says will require a housing strategy/masterplan, and are intended to be delivered at the same time and rapidly in order to help facilitate the development of the site to the north of Baldock (BA1 Blackhorse Farm). However, if they are delivered as a set of separate developments, even with the planning that has already been done, there is a risk that matters such as open space, leisure facilities, shopping, transport and infrastructure requirements will be considered separately rather than in aggregate resulting in insufficient facilities and infrastructure being created as a result of the developments. In other words, by developing so many sites, so close to each other, around an existing community, but doing so separately it looks as if the Plan deliberately attempts to separate out the considerations of the requirement for new facilities and infrastructure and deliberately sets out to result in under-supply - or at least to allow this to be possible without contradicting the plan. Since planning for these developments appears to be well under way (since these sites are intended to be developed first and rapidly, and from comments made by district and county councillors at Local Plan information meetings) then the creation of a master plan/strategic proposal for these sites should be possible with little or no impact to the schedule and deliverability of the plan, but with significant improvement on the sustainability of the resulting development of Clothall Common.

A large part of this site lies very close to Baldock train station and the direct fast (34 minutes) link to Kings Cross. This area has not previously been developed because it has until now been protected by Green Belt. Releasing land for development so close to the train station will in fact provide housing against London housing need rather than against North Hertfordshire housing need. It seems this has been missed by the Sustainability Review, presumably because they have assumed that all new development will fall under the Stevenage housing market area, which itself is based on an assumption of natural organic growth where areas of high desirability (such as those close to the train station) will already have been developed - but release of such a large section of land so close to the train station is quite exceptional and this should have been considered. Without mitigation this site will not deliver against North Hertfordshire housing need and risks increasing local house prices - exacerbating problems rather than improving them. The simplest mitigation is to maintain a strip of land (20 minutes walk from the train station) as Green Belt and so separate the new development from Baldock, the number of homes in this site should be reduced accordingly - alternatively, this policy needs to state that this strip of land will be developed only after all the rest of the site has been developed (allowing house prices to grow slowly and only the last set of homes risk being consumed solely against London housing need).
Furthermore, this is a very large site that is intended to be developed rapidly (with a dependency on other developments, like transitional school provision in Baldock Town and Clothall Common). Recent experience (for example, Great Ashby or the Church Gate development) do not show a competency within the district and county councils for successfully delivering this. It is too risky and should be scaled back. The remaining homes should be found via a more even spread across the district (for example by reconsidering sites that were in previous iterations of the plan) - this plan includes too much development around Baldock (an 80% increase in size!) too rapidly to be likely to be delivered sustainably or effectively. Especially considering that facilities and infrastructure in Baldock is already overstretched - school places are already over subscribed, GP surgery is at capacity, and road infrastructure is constrained by pinch points at narrow historic roads and junctions bounded by listed buildings hundreds of years old - these roads simply cannot be widened, and there is no guarantee the modest improvements suggested in the plan will effectively mitigate against traffic and infrastructure problems. This plan is currently planning to fail and should be scaled back at this site and housing spread more evenly among a greater number of smaller sites around North Hertfordshire.

The number of self-build plots should be increased - over the time of the plan, these will provide an affordable housing option and will be deliverable. This should be at least doubled to 56 plots.

4.177 The location of the site means it will be relatively close to the town centre and very close to the train station - the sustainability of building so close to a train station a direct fast (34 minutes) link into central London is arguable when it is likely that homes near the train station (within a 20 minute walk) will in fact go to meet London housing need instead of local housing need and will likely drive up house prices - it cannot be argued that encouraging inward migration, without supply of sufficient housing for local housing need and the driving up of house prices and making housing more unaffordable is sustainable development. The plan should accept that development close the train station is not good in terms of sustainable development, local house prices and meeting local housing need, and should indicate what mitigations will be put in place to prevent housing close to the train station simply being consumed by demand from London and the subsequent uplift in house prices. The strip of this site that lies with 20 minutes walk of the train station should be left undeveloped, or left until the rest of the site has been fully developed (i.e. until after 2031) in order that this site can maximise its benefit to the people of North Hertfordshire.

Re: point h of SP14.
It should be noted that Baldock is not very large and has an established secondary school, Knights Templar, which may be able to expand to provide the required provision. The plan should be careful not to presuppose the building of a new secondary school as the best solution, but development of this site should certainly contribute to the required provision, either by building of a new secondary school or by expansion and improvements to Knights Templar, or a combination of both.

SP14, point 4.178 states that development will not errode gaps between towns. It should be noted that the development will run right up to Bygrave Common, obliterating the character of Bygrave as a separate place from Baldock. Mitigations, such as a strip of green belt or undeveloped land between the two should be mentioned in the plan and considered as part of any development on this site.

I support the requirement for a site masterplan, for additional neighbourhood provision and for structural planing at this site. I support the construction of a road connecting the A507 London Road to the A505 Baldock bypass. I support the construction of a secondary rail crossing for pedestrians and cyclists, and safe access routes to/from Baldock station. I support integration of existing rights of way, which should be maintained as green spaces. I support the requirement of a community hall and GP surgery. I support the provision of new primary school on this site.

This policy should formally accept self-build as a kind of housing delivery that can be more affordable and should be an important inclusion in any affordable housing strategy.