Local Plan 2011-2031 Proposed Submission Draft

I support active attempts to increase the proportion of housing in the district, and in each town within the district, for sheltered and supported housing. There is an under-provision, but also this is vital to a sustainable strategy to deliver affordable housing by allowing existing under-occupied homes to be released and made available whilst providing more appropriate housing and conditions for more elderly residents of the district. There needs to be large increase in this sort of accommodation particularly those that provide separate housing units with a large degree of independence, in every town in the district. This needs to be of a high quality (low quality or high density provision is likely to be counter-productive as it will provide undesirable conditions that will discourage people from moving, particularly from moving out of larger, more under-occupied homes which are the most unaffordable in North Hertfordshire currently).

There needs to be a large increase in this sort of accommodation, particularly in separate housing units that provide full independence, in every town in the district. It needs to be high quality and low density, to encourage transition from larger, more under-occupied properties, so as to release these vital properties to new families in the district.

The plan remains largely unchanged from the Preferred Options Plan. Despite record levels of participation, the sites, distribution and volumes of development remain unchanged (in fact they have slightly increased and are slightly more disproportionately spread). Policies have been strengthened, but they are still vague and aspirational, rather than concrete and unambiguous - unless they are strengthened, perhaps with examples, then they will be easily pushed aside by the planning and development process and rendered irrelevant. Since there is so little change from the Preferred Options Plan, this raises a question mark over the consultation exercise. If they are not available already, the Planning Inspector should consider asking to see the comments raised against the Preferred Options Plan - these remain relevant as the vast majority of comments were about the location, distribution and volume of development sites (which are almost entirely unchanged). It feels like the Preferred Options Plan, rather than being a genuine consultation, was an exercise in manufacturing urgency. It has succeeded. Like many in North Hertfordshire I have no desire for our district to be left without a development plan (either a 5 year land release plan or a full Local Plan) and I fear the dangers of speculative development in the absence of a Local Plan. For this reason I will not be re-raising objections to the plan as a whole or the disproportionate distribution and volume of development contained within it; I will be limiting my comments as much as possible to areas of North Hertfordshire I know best and to specific elements of the plan that most affect me. This does not mean that the distribution and volume of development described in this Local Plan are any more proportionate, sustainable or desirable than they were in the Preferred Options Plan, but that I think it is important that a valid plan is now put in place. For this reason I think the Planning Inspector should look at the comments raised on the Preferred Options Plan and should recommend any adjustments to the Local Plan that might ensure a more proportionate and sustainable (and less risky) plan is put in place, rather than rejecting it out-right.
In respect to the specific policies affecting the areas of North Hertfordshire that I know well and that affect me most closely, I see a marked improvement over the previous version in the Preffered Options Plan.

The point "Creation of appropriate, defensible Green Belt boundary along south-western perimeter of site;" appears to be incorrectly worded. Land to the south-west is currently developed (apart from a tiny strip to the south), this probably means to the "south-eastern and south-western perimeter of the site" and should be corrected.

A policy should be added against BA3, that any housing should be in keeping with rest of the Clothall Common, particularly the use of green strips between housing, the planting of trees, and the mix of large and small housing.
A deliberate attempt should be made to keep any housing element of this site in keeping with the rest of Clothall Common - it should have green paths, separating different closes and should be mixed in terms of housing (both large and small houses) - this will with cohesion between existing and new developments and the sense of local community.

Recognition of the hill to the east of Clothall Common, between the A505 and Royston Road, as a recreational space should be incorporated into the plan, into the site maps, or at least as a policy against sites BA3 and BA4 stating that this recreational space and its use as such will be considered when designing or assessing developments or roads, etc.
To the north-east of this site, between Royston Road, the A505 and the north-eastern edge of Clothall Common is an undeveloped hill that rises above Clothall, with footpaths leading to site BA1 and Bygrave Common, and across the A505 toward Wallington. This site is highly utilised by residents of Clothall Common and Baldock Town - it provides a route for jogging and a place for kite flying and represents the only area of open recreational space on this side of Baldock (Clothall Common is run through with green strips, but in keeping with its history as a local forested common these areas are forested - there is nowhere on this side of Baldock for people to play football or other outdoor recreational activities). As part of this Plan it would be very sensible to recognise this hill as a specific recreational space and give it a status as such - for example as a park. This would have a big impact on the available open recreational space on this side of Baldock and at relatively little overall impact/cost to the Local Plan - a 'quick win' to make the Local Plan more sustainable. Also, recognising its importance as a recreational space would help ensure this is considered when designing the link road.

The Policy "Deliver, in combination with Site BA4, a southern link road connecting Wallington Road to B656 Royston Road" should be removed and replaced with "A southern link road connecting Clothall Road to the roundabout with the A505 slip road and the B656 Royston Road will be delivered, which will not run adjacent to existing boundaries or green areas".
Also a policy should be added for site BA3 that the position of the link road and its setting (e.g. lighting) should be sensitive to the existing Clothall Common development and the rural feel of the perimeter of Baldock (for example by running adjacent to the A505 and without lighting outside of the built up areas).
The most sensible path for the link road would be to run adjacent to the A505 from the bridge over the A505 (near the eastern corder of site BA2) on the A507 Clothall Road all the way to the existing roundabout to the slip road onto the A505 and Royston Road (next to site BA10 and the furthest eastern corner of the 'hill'). Also, the road should be unlit for the part that raises along the 'hill', i.e. the part that is outside of the built up area - this is important because the hill rises above Clothall Common and is visible throughout this whole part of Baldock and across into Baldock town - leaving it unlit will minimise its impact on these areas and maintain the rural feel of the perimeter areas of Baldock. This is a small element of the plan, which if ignored could have a large negative impact on a large number of residents of Baldock, but can be easily remedied.

A policy should be added for site BA3, that in consideration of the existing lack of outdoor sporting/playing field space on this (eastern) side of Baldock, consideration must be given to the creation of new outdoor playing field or sporting facilities at this site.
The north-east corner of site BA3 is actually the bottom of a hill that rises steeply up to the pedestrian bridge that crosses the A505. The bottom edge of the hill switches from roughly flat to steeply rising along a line that runs straight along the eastern edge of the Clothall Common and continues in a straight line north splitting site BA4 in half and south cutting through the eastern edge of site BA3. This triangle is not very appropriate for housing because of the slope and the impact it would have on the surrounding area - however, it is quite small and might make a suitable site for a play park or tennis courts or some other form of open outdoor activity/sporting area. In fact, as already mentioned there are no sites for outdoor sports or playing fields anywhere near this (eastern) side of Baldock. Development of site BA3 creates an opportunity to add additional recreational space improving the sustainability of this plan. This is all the more feasible in combination with a solution for education needs at the site.

The incorporation of the former Wallington Road (footpath running north east along the north edge of this site) is a very good suggestion and I endorse it. It maintains the existing access to the countryside and will encourage continued access, it is also in keeping with the existing Clothall Common development (the area to the north-east of the roman ruins and south of Royston road), which is crisscrossed with green paths (remnants of the common previously on this site).

The plan needs to be clear that the southern link road will not run alongside the existing boundary of Clothall Common and through the middle of site BA4, effectively cutting off the 'hill' (which is a highly utilised recreational space) from residents and placing the homes of site BA4 on a busy through route, but will instead run the road adjacent to the A505 all the way from the A507 Clothall Road (just after it crosses the A505) to the existing roundabout with the A505 slip road and Royston Road.

The Policy "Deliver, in combination with Site BA3, a southern link road connecting Wallington Road to B656 Royston Road" should be removed and replaced with "In combination with site BA4, a southern link road connecting the A507 Clothall Road to the roundabout with the A505 slip road and the B656 Royston Road will be delivered, which will not run through site BA4 or adjacent to existing boundaries or green areas".
The link road should not run through this site. To do so it would need to run from site BA3 along the eastern edge of Clothall Common - this would have a massive impact on the homes along that edge and takes no account of the existing strip of green forested land that runs along that edge between the existing homes and the ditch at the bottom of the hill to the east of Clothall Common. This strip of managed green is utilised by joggers, dog walkers and also by children in those houses - placing a (potentially very busy) link road along it would have a massive negative impact. It would also separate residents of Clothall Common and Baldock Town from the hill that rises to the east of Clothall Common, between the A505 and Royston Road. As already mentioned this hill is a highly utilised recreational space, used for a range of activities. It would also mean that the new homes at site BA4 would be built alongside a busy through route - by design - with all the noise and other environmental effects this would have on the site. Site BA4 lies adjacent to Royston Road and the relatively modest number of homes on this site can be accessed via Royston Road.
Instead the link road should run adjacent to the A505 from site BA3 (directly from the A507 Clothall Road where it passes over the top of the A505, and so avoiding Wallington Road and the roundabout with South Road, which is a very narrow road) up to the existing roundabout with the slip road for the A505 and Royston Road. This will dramatically reduce the impact this road will have on the residents of Clothall Common and the new residents of site BA4. It would maintain the quality of the green strip that runs through the eastern edge of Clothall Common and it would encourage the continued use of this 'hill' as a recreational space, contributing to the well being of residents and the sustainability of the plan.

A policy should be added to site BA4 as follows: "Incorporate alignment of the eastern edge of Clothall Common, running north through this site as a green corridor linking to the same that runs along the northern edge of site BA3 (the south-eastern edge of the existing Clothall Common)"
In addition, the plan should recognise the green forested strip that runs along the eastern edge of Clothall Common, in the same way that it recognises the green strip and footpath the runs along the southern edge (the old Walling Road footpath mentioned in Site BA3).

This site includes a green strip that links (on the opposite side of Yeomanry Drive) to a green strip that runs all the way through the middle of Clothall Common. Together this forms a green strip that runs from the other side of Clothall Common all the way to Footpath Baldock 036. This green strip and the link it provides from the footpath to the heart of Clothall Common should be acknowledged by the plan, otherwise it is likely that it will simply be built over as part of this development.

This seems like a sensible development and I support it.

There is evidence that insufficient planning has been done with respect to the large, ambitious development north of Baldock. For example, other stakeholders have not been contacted to ensure these plans are in fact feasible. The district and county council lack the competency maturity to deliver a project of this size and speed, and given the lack of preparation (in the face of an "it'll be alright" attitude) then this site should be scaled back to ensure it is deliverable and sustainable.
I am concerned about how well prepared this plan is. For example, in the recent GoVia proposal to change the timetable for their lines (including services through Baldock) it became apparent that neither the district nor the county council had contacted them to indicate that Baldock may be growing by 80% with many homes close to the train station and so a doubling (approximately) of journeys. Also, it turns out that in producing the preferred options plan, the Network Rail/rail infrastructor owners had not been contacted even though the plan assumed the construction of a new rail bridge and increased traffic (motor and pedestrian) under the existing narrow bridge by the train station. However, in public meetings in response to questions we had been assured that rail infrastructure and train operating organisations had been contacted in constructing this plan. This being so, then the plan should be designed so as to minimise risk in the face of poor preparation from the district council/planners. An ambitious and challenging plan would be dangerous given the evidence of poor preparation. (Especially, given recent local track-record/experiences: e.g. Churchgate development in central Hitchin, or the overdevelopment Great Ashby, Royston and even nearby Stotfold and the schools chaos that have ensued - particularly at Great Ashby.)
Proximity of the London housing market and the fast direct train links from Hitchin, Letchworth and Baldock train stations mean that any development too close to the train stations will simply be consumed by London housing need and push up prices and leave local need unmet. Natural organic growth of town with limited release of Green Belt, the separation of the new development north of Baldock from Baldock (and the train station) and the creation of 2 new towns (even if only started) is a better plan.
The elephant in the room in terms of development in North Hertforshire is the proximity of London and the London housing market and the rail link that provides an exceptionally fast connection straight into central London and the far greater salaries available there. As I understand it, the Local Plan has a duty to provide for the local housing need arising from those already living and working in North Hertfordshire and the surrounding areas, and for natural organic growth, through population growth and immigration from other areas. However, any development with a 20 minute walk of the train stations within North Hertfordshire up to and including Baldock will actually cater for London housing need, for those wishing to move out of London but continue to work in London. Hitchin, Letchwoth and Baldock train stations provide a link to London of 30 minutes approx. which combined with a short walk or tube ride on either end this is lower than many commutes within London and not much higher than the average intra-London commute. Furthermore, such developments will create an upward pressure on property prices in North Hertfordshire, not only from the raised house prices of these developments themselves, but also from the remaining unmet need. In short building too close to Hitchin, Letchworth or Baldock train stations will not meet local housing need and will actually make matters worse by raising house prices and leaving housing need unmet and rising. The best solution is natural organic growth of existing towns with limited release of Green Belt, combined with new settlements situated away from these train stations. For example, a Garden Village in the proposed Blackhorse farm site (north of Baldock), separated by Green Belt from Baldock could provide a significant number of homes - this is a change to the existing plan that could be made with limited affect on the overall plan. A new Garden Village at Odsey, that could grow over time into a Garden Town, and also a new Garden Village half way between Luton and Stevenage (not connected to London by a direct rail link), that also could grow into a Garden Town, are options that should should be included in the plan as desirable options - with respect to these options little work has been done by the district council to-date and these developments could not be counted against projections of housing to be delivered by this plan, but they could be specifically mentioned in the Local Plan so that as it is reviewed and revised over the period of the plan then progress against the development of these new villages/towns can be assessed, and development in other parts of North Hertfordshire can be adjusted accordingly. They would provide contingency and flexibility in the plan that is currently missing. I believe this would also be consistent with current government policy with regard to the creation of new Garden Cities and I believe NHDC has finally, belatedly started doing work on this. This offers NHDC a way out of the current disproportionate and quite unworkable plan (given the size and speed of the intended development at Baldock) and toward a more proportionate and workable plan over the period of the plan's operation - I feel that it provides a means that the plan can be altered and accepted by the Inspector, such that there is a proportionate, sustainable and workable Local Plan in place for North Hertfordshire.
Development remains disproportionate around Baldock (and in fact far from the areas of employment and areas of need to the west and south of the district). 2010-11 census data shows Baldock as having a population of 10,280, living in 4,491 homes (this is as a result of dramatic grow in the 80's with the Clothall Common development and then after this from significant infill development all over Baldock, particularly near the high street and the train station). The plan as-is would add an additional 3,590 (sites BA1-BA11) homes - this is an increase in size of 80% over 15 years. This is, quite frankly, planning to fail - it will be incredibly challenging to grow Baldock in a sustainable manner at such a rate (leaving aside concerns that much of this is close to the train station and will do little to address local housing need and will simply increase house prices). Any reduction in this overall number around Baldock will have a positive effect on the deliver-ability of the plan, will lower the risk and will make it more sustainable. I am not against development around Baldock. I would ideally like to see between 1000 to 1500 new homes added, with some of this delivered around Baldock and some of this delivered via a new Garden Village within the Blackhorse farm site, but separated from Baldock and Bygrave by Green Belt, and more than 20 minutes walk from the train station to ensure these houses actually address local housing need (instead of London housing need); However, if more than this is required, then every home must be justified against the increased risk, and decreased deliver-ability and sustainability of the plan, and against the possibility of using other sites around North Hertfordshire (for example sites that were considered in earlier versions of the plan prior to the preferred options plan).
Plan is disproportionate and involves a over-development of Baldock - increasing its size by 80% in a short time-frame. It is not deliverable (and the evidence to support it is not compelling, it is flawed by for example not adequately considering traffic constraints in Baldock). Site north of Baldock should be scaled back to reduce risk and increase deliver-ability and sustainability of the plan.
Traffic strategy for developments around Baldock is weak and does not support such ambitious development. Baldock has narrow traffic pinch points bounded by historic buildings and all traffic must run through these points - making it intolerant to even small fluctuations in traffic (there are regularly traffic jams). The north and south link roads suggested will help mitigate against increased traffic from these developments, but there is no evidence it will be sufficient. It is extremely optimistic to assume so. Development of site north of Baldock should be scaled back and separated from Baldock.
Traffic strategy is weak. There does not appear to be a valid traffic assessment or strategy covering Baldock, yet this is where the most dramatic development is planned to occur. As no doubt others will have pointed out the traffic lights between Station Road, Royston Road, Clothall Road and Whitehorse Street is a pinch point in the Baldock roads system. It is regularly clogged with traffic, including commuters dropping off/parking at the train station, parents doing the school run, and through traffic heading to Letchworth and beyond, or to the A505 and Royston, or along the 507 in either direction (to the A1 north or to Bedford, or to the south and along which traffic volumes have been growing - see the campaign Safer 507 which aims to change the status of the road from A road to B road) or heading through Baldock to the A1 south. This junction is bounded by listed buildings, hundreds of years old and there are no sensible options for enlarging this junction. Furthermore, it is not the only pinch point in Baldock, from the mini-roundabout at the top of the high-street along the B656 Hitchin Street is a narrow road bounded by historic buildings (again hundreds of years old) and forms the main route to Letchworth and beyond. Whilst at the other end of the High Street, South Road runs from the roundabout with the A507 (near Tapps garden centre) to the roundabout with London Round (outside Tesco Supermarket), which is a very narrow road providing the only other reasonable route from the east of Baldock to London Road and out to the A1 south. Adding to this, the main route north to the A1 is from the crossroads (mentioned above) along station road to North Road, which goes under a very narrow rail bridge, where traffic is often queued. The large development to the north of Baldock runs a serious risk of causing traffic chaos. The southern and northern bypasses suggested in the plan will be a great help (although it is unclear at which point in development they will be built) and they should certainly partially mitigate against traffic at the pinchpoints in Baldock, but it is unclear how well this will mitigate against the extra traffic produced by development around Baldock - greater work should have been done before plunging in for such a dramatic enlargement of Baldock. It should also be noted that all the development planned around Baldock is to the east, meaning traffic will need to flow through Baldock on its way through or out - very few people will be travelling north east to Royston, most will be travelling west and south toward Letchworth, Hitchin, Bedford, Luton and Stevenage. This is a key weakness in the plan as a whole - that development is planned almost as far away as possible from existing large areas of employment (and entertainment). The development to the north of Baldock should be scaled down and separated from Baldock as an effective way to reduce the risk inherent in the current plan. If the risk fails to materialise or is well mitigated by the northern and southern bypasses then the plans for Baldock can be scaled up over the course of the plan or even the next plan, but to assume, contrary to the local road layout, geographical constraints and historical traffic problems that everything will be fine, is planning to fail.

Need to increase the number of self build plots. Need to contact self build groups early to allow them time to organise. Self build is more affordable, provides tighter nit communities, creates housing with more character and is more sustainable.

13.27
This should be amended to be "provision of a new secondary school, or expansion of Knights Templar, or combination of both".
The new site creates a large requirement for additional provision and development of this site should make this provision available - however, it might be best to do this largely or even entirely through expansion and improvement of Knights Templar. The plan must not inadvertently exclude this as a possibility - it simply needs to ensure that provision is provided by the best means and is provided as a result of relatively early stages of this development.
13.29
South Road, which runs from the small roundabout on Clothall Road (with Wallington Road) to the large roundabout at the top of the High Street (with London Road) is a very narrow road. The new southern link road must not join with this directly, so as to encourage any traffic down South Road. Instead the new southern link road should run adjacent to the A505 from Clothall Road (some way south-east of the small roundabout with Wallington Road) up to the existing roundabout at the top of Royston Road (joining to the slip road to the A505).
Re: Point 13.30
The southern link road should not pass through BA4 (as commented against that site). Access to site BA4 would be direct from Royston Road, and with relatively few residents on this site there is no need for the link road to run through this site - in fact it would create through traffic, noise and environmental effects for the residents of that site, by design, rather than avoiding it. This point should not mention BA4, or add the words possibly BA4 to avoid the positioning of the road becoming a forgone conclusion as a result of this Local Plan.