Local Plan 2011-2031 Proposed Submission Draft

Please note that this representation has been made by email as the software provided by NHDC is unworkable. Queries raised about how it should be used (on 6th November) have not been answered.

This representation comments on SP8 and SP14

We do not wish to comment on whether the plan is legally compliant
We do consider that this plan is UNSOUND.
IT IS NOT JUSTIFIED, NOT EFFECTIVE and is NOT CONSISTENT WITH NATIONAL POLICY

We are not against housing as such and welcome house building in the area if it can be properly planned to enable the existing town to thrive. We endorse all the comments that have been made in the SRB representation. We would also like to use our own representation to reinforce the issues that affect BA1. We urge the inspector to make a site visit to BA1, preferably during the morning peak period to see the current challenges of accessing the town from the North.

As residents of North Road we witness the daily queues that form Southbound on North Road, morning and evening, the hazardous route that pedestrians have to take under the railway bridge to reach the town centre and the regular hits by lorries on the bridge. Clearly site BA1 cannot be developed without significant highway and infrastructure being developed in advance of any housing. Given the, as yet, unknown costs for obtaining rights to cross the railway line, developing the new road bridge (or tunnel?) and pedestrian route under the railway and the lack of proper traffic assessment for North Road, it is by no means certain that this site can be delivered in the local plan period. THIS PLAN IS THEREFORE NOT EFFECTIVE AS IT IS NOT DELIVERABLE OVER THE PLAN PERIOD.
This view is evidenced by...
1. WYG Appraisal, Land North and South of Baldock November 2014
2. Local Plan Model Testing 60271338 says in para 2 Baldock and Letchworth have not been tested to date.
3. Section 7 of AECOM's transport model

There are significant disadvantages to development of this magnitude in Baldock. Air quality will deteriorate to below acceptable standards. Integration with rest of Baldock will be extremely difficult - there are no proposals to create any direct routes from BA1 to the town centre thus causing most pedestrians and cars to opt for the most direct route, which will remain the existing North Road, narrow bridge and awkward junction at Whitehorse Street, in spite of the two new link roads that are proposed. The roads in the centre of the town will not cope with the additional traffic and will become gridlocked, ruining the functioning and character of the town itself. This site is no better than the area earmarked for future development West of Stevenage. In fact the West of Stevenage site has the advantage of being closer to the centres of employment, with easier access to high quality railway services for residents to commute out of the area, to London and putting less pressure on the already problematic A1M. THIS PLAN IS THEREFORE NOT JUSTIFIED AS THE MOST APPROPRIATE STRATEGY, WHEN CONSIDERED AGAINST THE REASONABLE ALTERNATIVES, BASED ON PROPORTIONAL EVIDENCE
These points evidenced by...
1. Local plan policy D4 Air quality policy,
2. Local Plan paragraph 9.28, air quality standards in Whitehorse St/Hitchin St
3. Housing and Green Belt Background Paper states that Priory fields was considered unsuitable for air quality reasons
4. WYG Appraisal, Land North and South of Baldock November 2014 marks the Whitehorse junction as restricting development

There is insufficient evidence to verify that development of BA1 will not cause a significant highway issues which cannot be resolved. THIS PLAN IS THEREFORE NOT CONSISTENT WITH NATIONAL PLANNING POLICY.
This is evidenced by
1. The comments made above
2. Paragraph 32 of the NPPF which states that "development decisions should take account of whether improvements can be undertaken within the transport network that cost effectively limit significant impacts of development."
3. Paragraph 177 of the NPPF which states that it is equally important that planned infrastructure is deliverable in a timely fashion.

The Change we would like to see in the Local Plan is the significant reduction in the number of houses planned for BA1 and for the West of Stevenage site to be reconsidered as the more appropriate location for the whole allocation being made to BA1. Evidence as above.

We do not wish to participate at the oral examination but urge the Inspector to call on SRB to give a resident's view of the Proposals.

We do wish to be notified when the local plan is submitted

Please note that this representation has been made by email as the software provided by NHDC is unworkable. Queries raised about how it should be used (on 6th November) have not been answered.

This representation comments on SP8 and SP14

We do not wish to comment on whether the plan is legally compliant
We do consider that this plan is UNSOUND.
IT IS NOT JUSTIFIED, NOT EFFECTIVE and is NOT CONSISTENT WITH NATIONAL POLICY

We are not against housing as such and welcome house building in the area if it can be properly planned to enable the existing town to thrive. We endorse all the comments that have been made in the SRB representation. We would also like to use our own representation to reinforce the issues that affect BA1. We urge the inspector to make a site visit to BA1, preferably during the morning peak period to see the current challenges of accessing the town from the North.

As residents of North Road we witness the daily queues that form Southbound on North Road, morning and evening, the hazardous route that pedestrians have to take under the railway bridge to reach the town centre and the regular hits by lorries on the bridge. Clearly site BA1 cannot be developed without significant highway and infrastructure being developed in advance of any housing. Given the, as yet, unknown costs for obtaining rights to cross the railway line, developing the new road bridge (or tunnel?) and pedestrian route under the railway and the lack of proper traffic assessment for North Road, it is by no means certain that this site can be delivered in the local plan period. THIS PLAN IS THEREFORE NOT EFFECTIVE AS IT IS NOT DELIVERABLE OVER THE PLAN PERIOD.
This view is evidenced by...
1. WYG Appraisal, Land North and South of Baldock November 2014
2. Local Plan Model Testing 60271338 says in para 2 Baldock and Letchworth have not been tested to date.
3. Section 7 of AECOM's transport model

There are significant disadvantages to development of this magnitude in Baldock. Air quality will deteriorate to below acceptable standards. Integration with rest of Baldock will be extremely difficult - there are no proposals to create any direct routes from BA1 to the town centre thus causing most pedestrians and cars to opt for the most direct route, which will remain the existing North Road, narrow bridge and awkward junction at Whitehorse Street, in spite of the two new link roads that are proposed. The roads in the centre of the town will not cope with the additional traffic and will become gridlocked, ruining the functioning and character of the town itself. This site is no better than the area earmarked for future development West of Stevenage. In fact the West of Stevenage site has the advantage of being closer to the centres of employment, with easier access to high quality railway services for residents to commute out of the area, to London and putting less pressure on the already problematic A1M. THIS PLAN IS THEREFORE NOT JUSTIFIED AS THE MOST APPROPRIATE STRATEGY, WHEN CONSIDERED AGAINST THE REASONABLE ALTERNATIVES, BASED ON PROPORTIONAL EVIDENCE
These points evidenced by...
1. Local plan policy D4 Air quality policy,
2. Local Plan paragraph 9.28, air quality standards in Whitehorse St/Hitchin St
3. Housing and Green Belt Background Paper states that Priory fields was considered unsuitable for air quality reasons
4. WYG Appraisal, Land North and South of Baldock November 2014 marks the Whitehorse junction as restricting development

There is insufficient evidence to verify that development of BA1 will not cause a significant highway issues which cannot be resolved. THIS PLAN IS THEREFORE NOT CONSISTENT WITH NATIONAL PLANNING POLICY.
This is evidenced by
1. The comments made above
2. Paragraph 32 of the NPPF which states that "development decisions should take account of whether improvements can be undertaken within the transport network that cost effectively limit significant impacts of development."
3. Paragraph 177 of the NPPF which states that it is equally important that planned infrastructure is deliverable in a timely fashion.

The Change we would like to see in the Local Plan is the significant reduction in the number of houses planned for BA1 and for the West of Stevenage site to be reconsidered as the more appropriate location for the whole allocation being made to BA1. Evidence as above.

We do not wish to participate at the oral examination but urge the Inspector to call on SRB to give a resident's view of the Proposals.

We do wish to be notified when the local plan is submitted