Local Plan 2011-2031 Proposed Submission Draft

We are writing to express our views about the Proposed Submission North Hertfordshire Local Plan 2011-2031.
Baldock is a rural, historic market town, the smallest town in the region, with more listed buildings than any others in the district. It has around 5,000 dwellings. If we get the proposed 3,590 more dwellings that would equate to a massive 80% increase. We feel this is a disproportionate increase that will adversely affect the nature and character of Baldock (see Green Belt section below). Also large settlements on the edge of the town with their facilities and local shops will compete with the existing shops and fragment the town; the heart of Baldock will be lost.
We should be thinking regionally and working co-operatively with others and with our neighbours. Houses do not make a community and a huge settlement of 2,800 as that planned for Blackhorse Farm is not viable. We need to find a suitable site for a new garden city. Baldock should be grown and expanded organically, not exponentially.
We have focussed our objections below on BA1, the Blackhorse Farm development, but many of these should be applied to Baldock in general.
Green Belt
The plots of land around the proposed Blackhorse Farm development (BA1) are all green belt. The NPPF government guidance states that green belt boundaries should only be altered in exceptional circumstances (para 82). There are none in this case. Green spaces around towns are crucial. The North Hertfordshire Green Belt Review states that these particular sites make a 'significant contribution' to the Green Belt purposes. It is short-sighted to simply move them to another area in the region. It is an essential part of the quality and character of the area and a fundamental part of the town's design. It should be protected. It enhances the high quality of life that people in the area currently enjoy.
The Blackhorse Farm site is an area of rolling countryside. A development this size would have significant adverse visible impact on the landscape. Once it has been built on, it is gone for ever. The NPPF states that the essential character of Green Belts are their openness and their permanence. They 'preserve the setting and special character of historic towns'. The development would also have a negative impact on the Ivel Springs local reserve and wildlife site. The sites around Bygrave Road are teeming with birdlife. Since 2012, there has been a large flock of resident starlings as well as house sparrows, finches, linnets, tits, pheasants and sparrowhawks.
This Plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. West of Stevenage should be reconsidered.
Road network
There are considerable existing congestion issues both locally in Baldock town and also on A1M. The current bypass was built and still there are continuing traffic problems with static traffic jams during peak travel times. With the new roads proposed to take traffic onto the Royston Road there will still be many commuters needing to travel through Baldock. The increase in the weight of traffic will cause further gridlock and put terrific strain on the road network. We already have a dangerous bottle neck under the narrow railway bridge in North Road where two people are unable to pass each other on the pathway and there are road safety concerns at the exit from Bygrave Road onto North Road.
Lorries are still adding to congestion problems by using North Road to access the A505 rather than using the bypass. How many times have lorries struck the railway bridge, despite the 'low bridge' warning? Many times, we have seen lorries inch through and only just clear the bridge. All of this delays traffic, especially if there is a bridge strike.
(In addition, the current weight limit of 7.5t in Bygrave Road would be insufficient for heavy plant vehicles used during construction).
The proposed new development on Blackhorse Farm relies on a new road bridge being built over the railway. We understand that Network Rail have no knowledge of this proposal; an assumption has been made where it is not clear if this is would be possible.
The A1M between junction 6 and 10 is unable to cope with the current capacity travelling during rush hour and changes are being put in place to try to alleviate this problem. But many houses are being built in Royston and more are proposed in the North Herts Local Plan which will all impact on the A1M corridor. It has no capacity to take more traffic.
The NPPF para 32 states that all developments that generate significant amounts of movement should be supported by a transport statement'. The proposed North Herts Local Plan refers to 'travel plans' on page 89 and 'measures to include' on page 61 but there are no details.
The Plan is not effective as it cannot be delivered in the plan period. It also fails the consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work.
Transport
The Plan makes no significant points other than the convenience of Baldock's location next to a station. The current train arrangements would not be able to cope with the proposed influx of new commuters not just at Baldock, but also from all along the Royston/Stevenage corridor. We understand that longer trains are proposed for the route, but the platform at Baldock will need to be extended. Where would these new commuters park? There is currently limited parking at the station. This would have an impact on local streets and cause displaced parking. Bringing in parking restrictions is not the solution. The town centre is already struggling due to parking restrictions. Where can the town centre workers park? Station facilities would also need to be improved as currently there are no provisions for those with disabilities or those with pushchairs, buggies etc.
The NPPF para 31 says local authorities should work with neighbouring authorities and transport providers for the provision of viable infrastructure. NHDC did not consult with Govia the current train provider, during the preparation of the Local Plan. Govia are themselves conducting a consultation about train services from 2018 onwards and were planning to reduce the peak service trains and are still intending to reduce the off-peak service.
The Plan is not effective as it cannot be delivered in the plan period. It also fails the consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work.
Employment
It will be impossible to create jobs locally for all the new residents in the town. There aren't enough jobs locally currently. There are plans for some industrial space, but the majority of residents will need to commute out of the area. Residents should be able to live sustainably near their place of work, not have to travel great distances. The NPPF para 34 states that 'plans and decisions should ensure developments that generate significant movements are located where the need to travel will be minimised'. Policy SP3 in the Local Plan describes the additional employment provision of 19.6ha of land East of Baldock. It also states that the Council will 'promote and support the expansion of the knowledge based economy in the District. Para 4.23 states that 'many higher skilled residents commute out of the District for employment.'
This Plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. West of Stevenage should be reconsidered. It also fails the criteria 4 ie it is not consistent with national policy as West of Stevenage has not been properly considered.
The NPPF para 28 says that planning policies should support economic growth in rural areas. It should 'promote a strong rural economy' and plans should 'provide the development and diversification of agricultural and other land-based rural businesses.' The proposed site at Blackhorse Farm means building on Grade 2 and 3 active and productive agricultural land. These rural agricultural businesses underpin the rural economy and the character of the landscape. We are encouraged to buy local and buy British, and to encourage UK self-sufficiency. It a strong message that will be undermined by destroying local agricultural land. The proposals will destroy the County Council small holdings on the fringe of Baldock, and will shatter the lives of those who work these areas. They are not just a dot on a map to be erased, they are someone's livelihood and home and it would also be an agricultural loss to the area. Once it has been eroded and developed, it cannot be reclaimed.
Air pollution
In paragraph 9.28, the Plan notes that air quality standards are already close to being exceeded in Whitehorse Street/Hitchin Street. The Housing and Green Belt Background paper notes that former site 209E (Priory Fields in Hitchin) was considered unsuitable for the same reason. Para 124 in the NPPF states that 'Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants.'
This Plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives (ref Priory Fields) and fails the criteria 4 ie it is not consistent with national policy on account of the likelihood of exceeding air quality limits.
Local facilities
Within the proposals there are plans for new schools and health facilities, but these will only be triggered by actual population numbers. So what happens in the meantime to all the new residents while they wait for numbers to reach a threshold? Local services would be unable to cope. We currently have no capacity in our schools and the doctors, hospital and police are all severely stretched. SP14 states that a masterplan must be produced prior to any other detailed matters. No detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added in September 2016) but it does not give detailed plans. Para 177 in the NPPF states that 'it is equally important that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan.'
This is not consistent with national policy as it has not assessed the costs of providing the necessary infrastructure and assumes that costs will be met by developers.
Amenities
We live in one of the most water-stressed areas of the country. The proposed site at Blackhorse Farm would have a huge impact on the local environment. Where would their water be sourced from and where would their sewage be treated? There are already capacity problems at the local sewage works and aquifier. In addition, the area has a known problem of frequent surface water flooding. The NPPF states that Local Plans should take account of flooding risk. This does not appear to be evident in the North Hertfordshire Local Plan.

In the Minister's foreword in the NPPF, he refers to 'sustainable development', 'change for the better', 'positive growth' and 'enhancing and improving where we live'. We need a Local Plan; we need housing for local people. We accept that Baldock will need to grow but the proposed numbers of dwellings are unacceptable. Baldock cannot take this kind of overdevelopment. Residents choose to live in this market town because of its rural character and the way of life it offers. We should protect and preserve its identity.
The proposals in the Proposed Submission Local Plan will irreversibly alter the character of the town, double its population, cause immense traffic flow problems on a heavily-congested road network, further parking problems and add infrastructure problems to our over-subscribed schools and limited healthcare facilities.
In respect of Baldock, The North Hertfordshire Local Plan is not sustainable. Exhaust all the brownfield sites in the area. Be innovative and creative and focus all efforts on a new garden city for the region.

We are writing to express our views about the Proposed Submission North Hertfordshire Local Plan 2011-2031.
Baldock is a rural, historic market town, the smallest town in the region, with more listed buildings than any others in the district. It has around 5,000 dwellings. If we get the proposed 3,590 more dwellings that would equate to a massive 80% increase. We feel this is a disproportionate increase that will adversely affect the nature and character of Baldock (see Green Belt section below). Also large settlements on the edge of the town with their facilities and local shops will compete with the existing shops and fragment the town; the heart of Baldock will be lost.
We should be thinking regionally and working co-operatively with others and with our neighbours. Houses do not make a community and a huge settlement of 2,800 as that planned for Blackhorse Farm is not viable. We need to find a suitable site for a new garden city. Baldock should be grown and expanded organically, not exponentially.
We have focussed our objections below on BA1, the Blackhorse Farm development, but many of these should be applied to Baldock in general.
Green Belt
The plots of land around the proposed Blackhorse Farm development (BA1) are all green belt. The NPPF government guidance states that green belt boundaries should only be altered in exceptional circumstances (para 82). There are none in this case. Green spaces around towns are crucial. The North Hertfordshire Green Belt Review states that these particular sites make a 'significant contribution' to the Green Belt purposes. It is short-sighted to simply move them to another area in the region. It is an essential part of the quality and character of the area and a fundamental part of the town's design. It should be protected. It enhances the high quality of life that people in the area currently enjoy.
The Blackhorse Farm site is an area of rolling countryside. A development this size would have significant adverse visible impact on the landscape. Once it has been built on, it is gone for ever. The NPPF states that the essential character of Green Belts are their openness and their permanence. They 'preserve the setting and special character of historic towns'. The development would also have a negative impact on the Ivel Springs local reserve and wildlife site. The sites around Bygrave Road are teeming with birdlife. Since 2012, there has been a large flock of resident starlings as well as house sparrows, finches, linnets, tits, pheasants and sparrowhawks.
This Plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. West of Stevenage should be reconsidered.
Road network
There are considerable existing congestion issues both locally in Baldock town and also on A1M. The current bypass was built and still there are continuing traffic problems with static traffic jams during peak travel times. With the new roads proposed to take traffic onto the Royston Road there will still be many commuters needing to travel through Baldock. The increase in the weight of traffic will cause further gridlock and put terrific strain on the road network. We already have a dangerous bottle neck under the narrow railway bridge in North Road where two people are unable to pass each other on the pathway and there are road safety concerns at the exit from Bygrave Road onto North Road.
Lorries are still adding to congestion problems by using North Road to access the A505 rather than using the bypass. How many times have lorries struck the railway bridge, despite the 'low bridge' warning? Many times, we have seen lorries inch through and only just clear the bridge. All of this delays traffic, especially if there is a bridge strike.
(In addition, the current weight limit of 7.5t in Bygrave Road would be insufficient for heavy plant vehicles used during construction).
The proposed new development on Blackhorse Farm relies on a new road bridge being built over the railway. We understand that Network Rail have no knowledge of this proposal; an assumption has been made where it is not clear if this is would be possible.
The A1M between junction 6 and 10 is unable to cope with the current capacity travelling during rush hour and changes are being put in place to try to alleviate this problem. But many houses are being built in Royston and more are proposed in the North Herts Local Plan which will all impact on the A1M corridor. It has no capacity to take more traffic.
The NPPF para 32 states that all developments that generate significant amounts of movement should be supported by a transport statement'. The proposed North Herts Local Plan refers to 'travel plans' on page 89 and 'measures to include' on page 61 but there are no details.
The Plan is not effective as it cannot be delivered in the plan period. It also fails the consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work.
Transport
The Plan makes no significant points other than the convenience of Baldock's location next to a station. The current train arrangements would not be able to cope with the proposed influx of new commuters not just at Baldock, but also from all along the Royston/Stevenage corridor. We understand that longer trains are proposed for the route, but the platform at Baldock will need to be extended. Where would these new commuters park? There is currently limited parking at the station. This would have an impact on local streets and cause displaced parking. Bringing in parking restrictions is not the solution. The town centre is already struggling due to parking restrictions. Where can the town centre workers park? Station facilities would also need to be improved as currently there are no provisions for those with disabilities or those with pushchairs, buggies etc.
The NPPF para 31 says local authorities should work with neighbouring authorities and transport providers for the provision of viable infrastructure. NHDC did not consult with Govia the current train provider, during the preparation of the Local Plan. Govia are themselves conducting a consultation about train services from 2018 onwards and were planning to reduce the peak service trains and are still intending to reduce the off-peak service.
The Plan is not effective as it cannot be delivered in the plan period. It also fails the consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work.
Employment
It will be impossible to create jobs locally for all the new residents in the town. There aren't enough jobs locally currently. There are plans for some industrial space, but the majority of residents will need to commute out of the area. Residents should be able to live sustainably near their place of work, not have to travel great distances. The NPPF para 34 states that 'plans and decisions should ensure developments that generate significant movements are located where the need to travel will be minimised'. Policy SP3 in the Local Plan describes the additional employment provision of 19.6ha of land East of Baldock. It also states that the Council will 'promote and support the expansion of the knowledge based economy in the District. Para 4.23 states that 'many higher skilled residents commute out of the District for employment.'
This Plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. West of Stevenage should be reconsidered. It also fails the criteria 4 ie it is not consistent with national policy as West of Stevenage has not been properly considered.
The NPPF para 28 says that planning policies should support economic growth in rural areas. It should 'promote a strong rural economy' and plans should 'provide the development and diversification of agricultural and other land-based rural businesses.' The proposed site at Blackhorse Farm means building on Grade 2 and 3 active and productive agricultural land. These rural agricultural businesses underpin the rural economy and the character of the landscape. We are encouraged to buy local and buy British, and to encourage UK self-sufficiency. It a strong message that will be undermined by destroying local agricultural land. The proposals will destroy the County Council small holdings on the fringe of Baldock, and will shatter the lives of those who work these areas. They are not just a dot on a map to be erased, they are someone's livelihood and home and it would also be an agricultural loss to the area. Once it has been eroded and developed, it cannot be reclaimed.
Air pollution
In paragraph 9.28, the Plan notes that air quality standards are already close to being exceeded in Whitehorse Street/Hitchin Street. The Housing and Green Belt Background paper notes that former site 209E (Priory Fields in Hitchin) was considered unsuitable for the same reason. Para 124 in the NPPF states that 'Planning policies should sustain compliance with and contribute towards EU limit values or national objectives for pollutants.'
This Plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives (ref Priory Fields) and fails the criteria 4 ie it is not consistent with national policy on account of the likelihood of exceeding air quality limits.
Local facilities
Within the proposals there are plans for new schools and health facilities, but these will only be triggered by actual population numbers. So what happens in the meantime to all the new residents while they wait for numbers to reach a threshold? Local services would be unable to cope. We currently have no capacity in our schools and the doctors, hospital and police are all severely stretched. SP14 states that a masterplan must be produced prior to any other detailed matters. No detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added in September 2016) but it does not give detailed plans. Para 177 in the NPPF states that 'it is equally important that planned infrastructure is deliverable in a timely fashion. To facilitate this, it is important that local planning authorities understand district-wide development costs at the time Local Plans are drawn up. For this reason, infrastructure and development policies should be planned at the same time, in the Local Plan.'
This is not consistent with national policy as it has not assessed the costs of providing the necessary infrastructure and assumes that costs will be met by developers.
Amenities
We live in one of the most water-stressed areas of the country. The proposed site at Blackhorse Farm would have a huge impact on the local environment. Where would their water be sourced from and where would their sewage be treated? There are already capacity problems at the local sewage works and aquifier. In addition, the area has a known problem of frequent surface water flooding. The NPPF states that Local Plans should take account of flooding risk. This does not appear to be evident in the North Hertfordshire Local Plan.

In the Minister's foreword in the NPPF, he refers to 'sustainable development', 'change for the better', 'positive growth' and 'enhancing and improving where we live'. We need a Local Plan; we need housing for local people. We accept that Baldock will need to grow but the proposed numbers of dwellings are unacceptable. Baldock cannot take this kind of overdevelopment. Residents choose to live in this market town because of its rural character and the way of life it offers. We should protect and preserve its identity.
The proposals in the Proposed Submission Local Plan will irreversibly alter the character of the town, double its population, cause immense traffic flow problems on a heavily-congested road network, further parking problems and add infrastructure problems to our over-subscribed schools and limited healthcare facilities.
In respect of Baldock, The North Hertfordshire Local Plan is not sustainable. Exhaust all the brownfield sites in the area. Be innovative and creative and focus all efforts on a new garden city for the region.