Local Plan 2011-2031 Proposed Submission Draft

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Object

Local Plan 2011-2031 Proposed Submission Draft

Policy SP8: Housing

Representation ID: 4139

Received: 29/11/2016

Respondent: NHDC Arbury Councillor

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object to SP8: Disproportionate allocation to Baldock, only a five-year land supply is required, two-step plan identifying sites to 2021 then a Garden City, use of Green Belt, failed to consider alternatives to the Green Belt.

Full text:

I have lived in this part of North Hertfordshire for over 17 years, the first couple in Baldock and then here in Bygrave. During this time I have come to appreciate and love this area and in particular the hamlet of Bygrave and the historic town of Baldock and their residents. What concerns me is that if the Local Plan 2011 -2031 (LP), and in particular the proposed BA1 site goes ahead, then Bygrave and Baldock as I know them will be destroyed and its residents abandoned by the organisation that should have their best interests at the forefront of their plans.

The Local Plan must be Sound. It should be:
Positively Prepared - it should meet objectively assessed development requirements;
Justified - it should be the most appropriate strategy;
Effective - it should be deliverable over its period; and
Consistent with national policy - it should enable the delivery of sustainable development in accordance with the policies of the NPPF.

I believe that the Local Plan is not sound. These are my reasons.

Missed opportunity
I fully support the need for new housing to meet the demands for homes for current residents and those in the future, but I have to object to the way in which the LP proposes to meet this need. The ONS figures say we need 14,400 houses in the period 2011 - 2031, together with an "unmet" need from neighbouring Luton of 2,100, making a grand total of 16,500. In order to achieve this total, the LP will almost double the size of Baldock, the smallest of 4 towns in the area, creating a competing community to this thriving market town.

Despite legal advice received that the minimum plan needed was a five year land supply, the LP has ignored this and NHDC have blindly continued down this flawed path to allow the building of 16,500 houses, 60% of which is to be built on Green Belt land.

I would argue that they should abandon this 20 year plan and look to a 2 step plan with the first phase a 10 year plan to provide 6050 houses by 2021. This proposal is supported by the three local MPS for this area, The Right Honourable Sir Oliver Heald, Peter Lilley and Stephen McPartland. Over 2600 houses already have planning permission so a further 3450 homes need to be identified by 2021. During this period, the development of a new Garden City could be pursued, creating a viable new community in itself instead of a "bolt on" development in direct conflict/competition with the existing towns. Although this may not be physically possible within the current plan timeframe, this should be seen as the way forward to achieving sustainable communities.

Transport
There are a number of failings in the plan in respect of road and rail travel. The NPPF states that "Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives".

There are already major issues with the main A507/B656 junction in the centre of Baldock. The crossroads, governed mainly by three way traffic lights, is regularly gridlocked and not just at peak times. No traffic surveys have been carried out to assess the effect of potentially 5000 extra cars wanting to come into Baldock. The junction may need to be re-designed, but as there are houses on two sides of the junctions that are listed having been built in 1540, this would seem impossible. The LP has failed to address this, leaving Baldock and Bygrave residents to face gridlock throughout the day should this development on BA1 go ahead.

The LP does have as part of the master plan for BA1 the requirement of a new link road connecting the A507 London Road to the A505 Baldock bypass including a bridge over the railway which could be argued will direct traffic away from the centre of Baldock. There are no clear plans as to the route of this road and the effect on the residents of Bygrave of the existing road into Baldock, and how this new road will be accessed from the site. Some people may use the new road to go onto the Baldock Bypass to Royston and some may use it to go down the bypass towards Letchworth Garden City and the A1. This will not alleviate the traffic problems in Baldock and will just add to the traffic on the bypass and increase the traffic jams towards the A1.

Another failure is that NHDC did not inform/co-operate with other parties in respect of its transport considerations. Network rail were unaware at the time of the Preferred Options Plan (2014-15) of the proposal to increase the population of Baldock by 80%, and more recently Govia Thameslink Railway, the train operator, were also unaware of this plan when it issued a consultation in September 2016 on reducing the number of trains serving Baldock. Govia have accepted that they now need to re-model their plans to take this into account. This approach is contrary to the NPPF (Promoting sustainable transport, para 31) which states that "Local authorities should work with neighbouring authorities and transport providers for the provision of viable infrastructure necessary to support sustainable development". It is apparent that NHDC failed to consider rail and private road transport issues and failed to talk to these parties that could have provided valuable input.

In addition to rail and private road travel, there is also an issue of a lack of bus services available to residents of Baldock and Bygrave, which particularly affects the older generation. No thought has been given to those who have to rely on public road travel nor co-operation with the relevant parties has been done by NHDC. The removal of the 98 bus between Baldock, Letchworth and Hitchin and the 391 service to Stevenage has adversely affected those without access to their own car, and this is especially an issue as our local hospital is in Stevenage.

Another major consideration, which the LP fails to take into account is the access to the site itself. There is no indication on the Master Plan for BA1 where the road access will be, but as two sides of the site are land locked, access is likely to be onto the main road into Baldock, the A507, which is already congested and on to Bygrave road, a rural road of poor quality. The NPPF says that the Plan should take account of whether "safe and suitable access to the site can be achieved for all people" but this appears impossible for this site.

I would argue that the development of the site at BA1 will create significant amounts of movement and therefore in accordance with the NPPF a Travel Plan should be required. This is not part of the Master Plan for this site.

In terms of "health objectives", the LP has failed to consider the increased pollution from the thousands of additional cars on the roads through Baldock. There is historical data which shows the link between air pollution and asthma. Baldock is situated in a valley which prevents the proper dispersal of air pollutants. There has been no specific assessment of air quality made in the preparation of this plan, yet 2800 family homes are being proposed where both adults and children could be at risk of asthma and other breathing conditions.

Green Belt
One of the major flaws in the LP is the use of Green Belt land for 60% of the proposed housing. This land is currently being used for agriculture, and its loss will not only mean the removal of beautiful countryside but also individuals livelihoods. The NPPF states "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence." The Government has reinforced this view recently and said that Green Belt should be used for development only in exceptional circumstances. Given the NPPF's essential characteristic of Green Belt as permanent, it is totally unjustifiable and unacceptable that the LP removes the Green Belt designation for BA1 and defends this by saying some other land will be designated as Green Belt to make up for this. If Green Belt is permanent then it should stay Green Belt.

The Government has also said that brownfield sites should be used before Green Belt land. In 2014 the Minister for Housing said "This government wants to see the maximum amount of brownfield land being used to build new homes, whilst also maintaining protections for our beautiful countryside". NHDC has failed to consider alternatives to the Green Belt, and in particular has failed to consult with North Herts Homes (NHH) Brownfield Regeneration Project which aims to provide 400 homes solely from brownfield sites in the period 2014 -18.

Loss of prime agricultural land
The building of housing on BA1 will also see the loss of prime agricultural land where crops and livestock have been nurtured for many years. These smallholdings have been part of the landscape of Baldock and faithfully worked by families for generations, who will now lose their homes and livelihoods. The NPPF (Supporting a prosperous rural economy, para 28) states that planning policies should support the rural economy and that local plans should: "promote the development and diversification of agricultural and other land-based rural businesses". The LP goes against this in its proposal to replace agricultural land with 2800 homes.

Adverse effect on wildlife
The BA1 development will also have a devastating effect on local wildlife with a number of endangered species at risk. The site is central to the Corn Bunting, a Red Listed bird which has become extinct in other parts of the UK and Ireland. Other Red Listed birds at risk include the Grey Partridge, Yellow Wagtail and Linnet. The removal of their habitat will see an adverse effect on their numbers, further threatening their very existence. This is contrary to the NPPF (Conserving and enhancing the natural environment, para 109)

Ivel Springs nature reserve
In Baldock we have a large nature reserve and Scheduled National Monument, Ivel Springs. The springs, which have been there for over 5,000 years, provide a wide variety of habitats for wildlife and is carefully managed to encourage as many species as possible. The Ivel is a chalk river, which is extremely rare and part of the Hertfordshire Biodiversity Action Plan. The Springs are already under threat and have dried up for the last six summers. The development at BA1 is likely to cause even more strain on the Springs it has been said, and the effect on the species and their habitat is unimaginable. The damage done by the development is unthinkable and before this is considered a thorough survey should be done to assess the threat to this treasured site.

Archaeological importance
Baldock is a well-known Roman town and in February 2015 NHDC were told by the National Historic & Built Environment Advisory Team that there could be heritage assets on the proposed BA1 site. As a result the landowner, Hertfordshire County Council, commissioned an archaeological dig to investigate the site. Archaeological remains have been found, which probably pre-date the Roman era. Investigations are continuing and there is news from the dig team that the finds include a Roman villa and wall paintings. These findings could be of great significance to our local history and puts the proposed development of BA1 into doubt.

I would urge you to listen to the residents of North Hertfordshire and agree that the two stage plan will provide sustainable development across the District as a whole which will enhance the lives of all residents of North Hertfordshire, both old and new.

Object

Local Plan 2011-2031 Proposed Submission Draft

Policy SP14: Site BA1 - North of Baldock

Representation ID: 6063

Received: 29/11/2016

Respondent: NHDC Arbury Councillor

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object to SP14: Green Belt, traffic, scale of development, lack of detailed plans for link road, impact of link road on travel patterns, no indication of road access, safe access cannot be created, travel plan required, loss of prime agricultural land, loss of rural jobs, biodiversity, presence of protected species, impact on Ivel Springs (nature reserve, SAM), potentially significant archaeological findings

Full text:

I have lived in this part of North Hertfordshire for over 17 years, the first couple in Baldock and then here in Bygrave. During this time I have come to appreciate and love this area and in particular the hamlet of Bygrave and the historic town of Baldock and their residents. What concerns me is that if the Local Plan 2011 -2031 (LP), and in particular the proposed BA1 site goes ahead, then Bygrave and Baldock as I know them will be destroyed and its residents abandoned by the organisation that should have their best interests at the forefront of their plans.

The Local Plan must be Sound. It should be:
Positively Prepared - it should meet objectively assessed development requirements;
Justified - it should be the most appropriate strategy;
Effective - it should be deliverable over its period; and
Consistent with national policy - it should enable the delivery of sustainable development in accordance with the policies of the NPPF.

I believe that the Local Plan is not sound. These are my reasons.

Missed opportunity
I fully support the need for new housing to meet the demands for homes for current residents and those in the future, but I have to object to the way in which the LP proposes to meet this need. The ONS figures say we need 14,400 houses in the period 2011 - 2031, together with an "unmet" need from neighbouring Luton of 2,100, making a grand total of 16,500. In order to achieve this total, the LP will almost double the size of Baldock, the smallest of 4 towns in the area, creating a competing community to this thriving market town.

Despite legal advice received that the minimum plan needed was a five year land supply, the LP has ignored this and NHDC have blindly continued down this flawed path to allow the building of 16,500 houses, 60% of which is to be built on Green Belt land.

I would argue that they should abandon this 20 year plan and look to a 2 step plan with the first phase a 10 year plan to provide 6050 houses by 2021. This proposal is supported by the three local MPS for this area, The Right Honourable Sir Oliver Heald, Peter Lilley and Stephen McPartland. Over 2600 houses already have planning permission so a further 3450 homes need to be identified by 2021. During this period, the development of a new Garden City could be pursued, creating a viable new community in itself instead of a "bolt on" development in direct conflict/competition with the existing towns. Although this may not be physically possible within the current plan timeframe, this should be seen as the way forward to achieving sustainable communities.

Transport
There are a number of failings in the plan in respect of road and rail travel. The NPPF states that "Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives".

There are already major issues with the main A507/B656 junction in the centre of Baldock. The crossroads, governed mainly by three way traffic lights, is regularly gridlocked and not just at peak times. No traffic surveys have been carried out to assess the effect of potentially 5000 extra cars wanting to come into Baldock. The junction may need to be re-designed, but as there are houses on two sides of the junctions that are listed having been built in 1540, this would seem impossible. The LP has failed to address this, leaving Baldock and Bygrave residents to face gridlock throughout the day should this development on BA1 go ahead.

The LP does have as part of the master plan for BA1 the requirement of a new link road connecting the A507 London Road to the A505 Baldock bypass including a bridge over the railway which could be argued will direct traffic away from the centre of Baldock. There are no clear plans as to the route of this road and the effect on the residents of Bygrave of the existing road into Baldock, and how this new road will be accessed from the site. Some people may use the new road to go onto the Baldock Bypass to Royston and some may use it to go down the bypass towards Letchworth Garden City and the A1. This will not alleviate the traffic problems in Baldock and will just add to the traffic on the bypass and increase the traffic jams towards the A1.

Another failure is that NHDC did not inform/co-operate with other parties in respect of its transport considerations. Network rail were unaware at the time of the Preferred Options Plan (2014-15) of the proposal to increase the population of Baldock by 80%, and more recently Govia Thameslink Railway, the train operator, were also unaware of this plan when it issued a consultation in September 2016 on reducing the number of trains serving Baldock. Govia have accepted that they now need to re-model their plans to take this into account. This approach is contrary to the NPPF (Promoting sustainable transport, para 31) which states that "Local authorities should work with neighbouring authorities and transport providers for the provision of viable infrastructure necessary to support sustainable development". It is apparent that NHDC failed to consider rail and private road transport issues and failed to talk to these parties that could have provided valuable input.

In addition to rail and private road travel, there is also an issue of a lack of bus services available to residents of Baldock and Bygrave, which particularly affects the older generation. No thought has been given to those who have to rely on public road travel nor co-operation with the relevant parties has been done by NHDC. The removal of the 98 bus between Baldock, Letchworth and Hitchin and the 391 service to Stevenage has adversely affected those without access to their own car, and this is especially an issue as our local hospital is in Stevenage.

Another major consideration, which the LP fails to take into account is the access to the site itself. There is no indication on the Master Plan for BA1 where the road access will be, but as two sides of the site are land locked, access is likely to be onto the main road into Baldock, the A507, which is already congested and on to Bygrave road, a rural road of poor quality. The NPPF says that the Plan should take account of whether "safe and suitable access to the site can be achieved for all people" but this appears impossible for this site.

I would argue that the development of the site at BA1 will create significant amounts of movement and therefore in accordance with the NPPF a Travel Plan should be required. This is not part of the Master Plan for this site.

In terms of "health objectives", the LP has failed to consider the increased pollution from the thousands of additional cars on the roads through Baldock. There is historical data which shows the link between air pollution and asthma. Baldock is situated in a valley which prevents the proper dispersal of air pollutants. There has been no specific assessment of air quality made in the preparation of this plan, yet 2800 family homes are being proposed where both adults and children could be at risk of asthma and other breathing conditions.

Green Belt
One of the major flaws in the LP is the use of Green Belt land for 60% of the proposed housing. This land is currently being used for agriculture, and its loss will not only mean the removal of beautiful countryside but also individuals livelihoods. The NPPF states "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence." The Government has reinforced this view recently and said that Green Belt should be used for development only in exceptional circumstances. Given the NPPF's essential characteristic of Green Belt as permanent, it is totally unjustifiable and unacceptable that the LP removes the Green Belt designation for BA1 and defends this by saying some other land will be designated as Green Belt to make up for this. If Green Belt is permanent then it should stay Green Belt.

The Government has also said that brownfield sites should be used before Green Belt land. In 2014 the Minister for Housing said "This government wants to see the maximum amount of brownfield land being used to build new homes, whilst also maintaining protections for our beautiful countryside". NHDC has failed to consider alternatives to the Green Belt, and in particular has failed to consult with North Herts Homes (NHH) Brownfield Regeneration Project which aims to provide 400 homes solely from brownfield sites in the period 2014 -18.

Loss of prime agricultural land
The building of housing on BA1 will also see the loss of prime agricultural land where crops and livestock have been nurtured for many years. These smallholdings have been part of the landscape of Baldock and faithfully worked by families for generations, who will now lose their homes and livelihoods. The NPPF (Supporting a prosperous rural economy, para 28) states that planning policies should support the rural economy and that local plans should: "promote the development and diversification of agricultural and other land-based rural businesses". The LP goes against this in its proposal to replace agricultural land with 2800 homes.

Adverse effect on wildlife
The BA1 development will also have a devastating effect on local wildlife with a number of endangered species at risk. The site is central to the Corn Bunting, a Red Listed bird which has become extinct in other parts of the UK and Ireland. Other Red Listed birds at risk include the Grey Partridge, Yellow Wagtail and Linnet. The removal of their habitat will see an adverse effect on their numbers, further threatening their very existence. This is contrary to the NPPF (Conserving and enhancing the natural environment, para 109)

Ivel Springs nature reserve
In Baldock we have a large nature reserve and Scheduled National Monument, Ivel Springs. The springs, which have been there for over 5,000 years, provide a wide variety of habitats for wildlife and is carefully managed to encourage as many species as possible. The Ivel is a chalk river, which is extremely rare and part of the Hertfordshire Biodiversity Action Plan. The Springs are already under threat and have dried up for the last six summers. The development at BA1 is likely to cause even more strain on the Springs it has been said, and the effect on the species and their habitat is unimaginable. The damage done by the development is unthinkable and before this is considered a thorough survey should be done to assess the threat to this treasured site.

Archaeological importance
Baldock is a well-known Roman town and in February 2015 NHDC were told by the National Historic & Built Environment Advisory Team that there could be heritage assets on the proposed BA1 site. As a result the landowner, Hertfordshire County Council, commissioned an archaeological dig to investigate the site. Archaeological remains have been found, which probably pre-date the Roman era. Investigations are continuing and there is news from the dig team that the finds include a Roman villa and wall paintings. These findings could be of great significance to our local history and puts the proposed development of BA1 into doubt.

I would urge you to listen to the residents of North Hertfordshire and agree that the two stage plan will provide sustainable development across the District as a whole which will enhance the lives of all residents of North Hertfordshire, both old and new.

Object

Local Plan 2011-2031 Proposed Submission Draft

Baldock

Representation ID: 6064

Received: 29/11/2016

Respondent: NHDC Arbury Councillor

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation Summary:

Object to Baldock (general): Impact on character of town and Bygrave, impact on A507 / B656 junction, traffic, no traffic surveys, lack of consultation with rail and bus operators, planned reduction in rail services, air pollution

Full text:

I have lived in this part of North Hertfordshire for over 17 years, the first couple in Baldock and then here in Bygrave. During this time I have come to appreciate and love this area and in particular the hamlet of Bygrave and the historic town of Baldock and their residents. What concerns me is that if the Local Plan 2011 -2031 (LP), and in particular the proposed BA1 site goes ahead, then Bygrave and Baldock as I know them will be destroyed and its residents abandoned by the organisation that should have their best interests at the forefront of their plans.

The Local Plan must be Sound. It should be:
Positively Prepared - it should meet objectively assessed development requirements;
Justified - it should be the most appropriate strategy;
Effective - it should be deliverable over its period; and
Consistent with national policy - it should enable the delivery of sustainable development in accordance with the policies of the NPPF.

I believe that the Local Plan is not sound. These are my reasons.

Missed opportunity
I fully support the need for new housing to meet the demands for homes for current residents and those in the future, but I have to object to the way in which the LP proposes to meet this need. The ONS figures say we need 14,400 houses in the period 2011 - 2031, together with an "unmet" need from neighbouring Luton of 2,100, making a grand total of 16,500. In order to achieve this total, the LP will almost double the size of Baldock, the smallest of 4 towns in the area, creating a competing community to this thriving market town.

Despite legal advice received that the minimum plan needed was a five year land supply, the LP has ignored this and NHDC have blindly continued down this flawed path to allow the building of 16,500 houses, 60% of which is to be built on Green Belt land.

I would argue that they should abandon this 20 year plan and look to a 2 step plan with the first phase a 10 year plan to provide 6050 houses by 2021. This proposal is supported by the three local MPS for this area, The Right Honourable Sir Oliver Heald, Peter Lilley and Stephen McPartland. Over 2600 houses already have planning permission so a further 3450 homes need to be identified by 2021. During this period, the development of a new Garden City could be pursued, creating a viable new community in itself instead of a "bolt on" development in direct conflict/competition with the existing towns. Although this may not be physically possible within the current plan timeframe, this should be seen as the way forward to achieving sustainable communities.

Transport
There are a number of failings in the plan in respect of road and rail travel. The NPPF states that "Transport policies have an important role to play in facilitating sustainable development but also in contributing to wider sustainability and health objectives".

There are already major issues with the main A507/B656 junction in the centre of Baldock. The crossroads, governed mainly by three way traffic lights, is regularly gridlocked and not just at peak times. No traffic surveys have been carried out to assess the effect of potentially 5000 extra cars wanting to come into Baldock. The junction may need to be re-designed, but as there are houses on two sides of the junctions that are listed having been built in 1540, this would seem impossible. The LP has failed to address this, leaving Baldock and Bygrave residents to face gridlock throughout the day should this development on BA1 go ahead.

The LP does have as part of the master plan for BA1 the requirement of a new link road connecting the A507 London Road to the A505 Baldock bypass including a bridge over the railway which could be argued will direct traffic away from the centre of Baldock. There are no clear plans as to the route of this road and the effect on the residents of Bygrave of the existing road into Baldock, and how this new road will be accessed from the site. Some people may use the new road to go onto the Baldock Bypass to Royston and some may use it to go down the bypass towards Letchworth Garden City and the A1. This will not alleviate the traffic problems in Baldock and will just add to the traffic on the bypass and increase the traffic jams towards the A1.

Another failure is that NHDC did not inform/co-operate with other parties in respect of its transport considerations. Network rail were unaware at the time of the Preferred Options Plan (2014-15) of the proposal to increase the population of Baldock by 80%, and more recently Govia Thameslink Railway, the train operator, were also unaware of this plan when it issued a consultation in September 2016 on reducing the number of trains serving Baldock. Govia have accepted that they now need to re-model their plans to take this into account. This approach is contrary to the NPPF (Promoting sustainable transport, para 31) which states that "Local authorities should work with neighbouring authorities and transport providers for the provision of viable infrastructure necessary to support sustainable development". It is apparent that NHDC failed to consider rail and private road transport issues and failed to talk to these parties that could have provided valuable input.

In addition to rail and private road travel, there is also an issue of a lack of bus services available to residents of Baldock and Bygrave, which particularly affects the older generation. No thought has been given to those who have to rely on public road travel nor co-operation with the relevant parties has been done by NHDC. The removal of the 98 bus between Baldock, Letchworth and Hitchin and the 391 service to Stevenage has adversely affected those without access to their own car, and this is especially an issue as our local hospital is in Stevenage.

Another major consideration, which the LP fails to take into account is the access to the site itself. There is no indication on the Master Plan for BA1 where the road access will be, but as two sides of the site are land locked, access is likely to be onto the main road into Baldock, the A507, which is already congested and on to Bygrave road, a rural road of poor quality. The NPPF says that the Plan should take account of whether "safe and suitable access to the site can be achieved for all people" but this appears impossible for this site.

I would argue that the development of the site at BA1 will create significant amounts of movement and therefore in accordance with the NPPF a Travel Plan should be required. This is not part of the Master Plan for this site.

In terms of "health objectives", the LP has failed to consider the increased pollution from the thousands of additional cars on the roads through Baldock. There is historical data which shows the link between air pollution and asthma. Baldock is situated in a valley which prevents the proper dispersal of air pollutants. There has been no specific assessment of air quality made in the preparation of this plan, yet 2800 family homes are being proposed where both adults and children could be at risk of asthma and other breathing conditions.

Green Belt
One of the major flaws in the LP is the use of Green Belt land for 60% of the proposed housing. This land is currently being used for agriculture, and its loss will not only mean the removal of beautiful countryside but also individuals livelihoods. The NPPF states "The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open; the essential characteristics of Green Belts are their openness and their permanence." The Government has reinforced this view recently and said that Green Belt should be used for development only in exceptional circumstances. Given the NPPF's essential characteristic of Green Belt as permanent, it is totally unjustifiable and unacceptable that the LP removes the Green Belt designation for BA1 and defends this by saying some other land will be designated as Green Belt to make up for this. If Green Belt is permanent then it should stay Green Belt.

The Government has also said that brownfield sites should be used before Green Belt land. In 2014 the Minister for Housing said "This government wants to see the maximum amount of brownfield land being used to build new homes, whilst also maintaining protections for our beautiful countryside". NHDC has failed to consider alternatives to the Green Belt, and in particular has failed to consult with North Herts Homes (NHH) Brownfield Regeneration Project which aims to provide 400 homes solely from brownfield sites in the period 2014 -18.

Loss of prime agricultural land
The building of housing on BA1 will also see the loss of prime agricultural land where crops and livestock have been nurtured for many years. These smallholdings have been part of the landscape of Baldock and faithfully worked by families for generations, who will now lose their homes and livelihoods. The NPPF (Supporting a prosperous rural economy, para 28) states that planning policies should support the rural economy and that local plans should: "promote the development and diversification of agricultural and other land-based rural businesses". The LP goes against this in its proposal to replace agricultural land with 2800 homes.

Adverse effect on wildlife
The BA1 development will also have a devastating effect on local wildlife with a number of endangered species at risk. The site is central to the Corn Bunting, a Red Listed bird which has become extinct in other parts of the UK and Ireland. Other Red Listed birds at risk include the Grey Partridge, Yellow Wagtail and Linnet. The removal of their habitat will see an adverse effect on their numbers, further threatening their very existence. This is contrary to the NPPF (Conserving and enhancing the natural environment, para 109)

Ivel Springs nature reserve
In Baldock we have a large nature reserve and Scheduled National Monument, Ivel Springs. The springs, which have been there for over 5,000 years, provide a wide variety of habitats for wildlife and is carefully managed to encourage as many species as possible. The Ivel is a chalk river, which is extremely rare and part of the Hertfordshire Biodiversity Action Plan. The Springs are already under threat and have dried up for the last six summers. The development at BA1 is likely to cause even more strain on the Springs it has been said, and the effect on the species and their habitat is unimaginable. The damage done by the development is unthinkable and before this is considered a thorough survey should be done to assess the threat to this treasured site.

Archaeological importance
Baldock is a well-known Roman town and in February 2015 NHDC were told by the National Historic & Built Environment Advisory Team that there could be heritage assets on the proposed BA1 site. As a result the landowner, Hertfordshire County Council, commissioned an archaeological dig to investigate the site. Archaeological remains have been found, which probably pre-date the Roman era. Investigations are continuing and there is news from the dig team that the finds include a Roman villa and wall paintings. These findings could be of great significance to our local history and puts the proposed development of BA1 into doubt.

I would urge you to listen to the residents of North Hertfordshire and agree that the two stage plan will provide sustainable development across the District as a whole which will enhance the lives of all residents of North Hertfordshire, both old and new.

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