Local Plan 2011-2031 Proposed Submission Draft

I am writing in response to the proposed Local Plan for Baldock in North Hertfordshire. I have presented my response below by referring to the National Planning Policy Framework and the Local Plan.

SP6 Sustainable Transport
With regard to the BA1 North of Baldock site, traffic congestion on the A507 has always been an enormous problem and it has been exacerbated since the opening of the Baldock by-pass in 2006. Increased traffic on the A507 from the BA1 site would encourage vehicles to use the single track Nortonbury Lane to access the town and severely compromise the safety and nature of this lane. A further concern is the dangerous double bend on the A507 at Mill Valley (that often becomes flooded in heavy rains) which would put at risk traffic and pedestrians using any proposed access road onto the BA1 site. The town has been described as an hourglass, with the crossroads of A505 and A507 at the pinch point, its centre. The listed buildings (dating back to the 1500s) at the junction make finding a solution virtually impossible. There are already tailbacks from this junction back along the A507, bordering the site where the BA1 North of Baldock site is planned. This occurs at most times of the day and particularly during morning and evening peak times. This has also been exacerbated by Sat Nav companies guiding lorries and other traffic along the A507 and through this junction. The traffic will increase by approximately 7000 cars generated from the new housing development as well as any additional commercial traffic. I attach photos taken on two consecutive days showing typical traffic jams stretching back along the A507 (from the junction with the A505). These are taken where the A507 borders the proposed BA1 north of Baldock site. All the town's amenities are at the other side of the town to the BA1 development and this will mean that cars will have to cross the very congested A505/A507 junction and add to the already heavy congestion to get to the town centre. NPPF Section 4 'Promoting Sustainable Transport' paragraph 32, states that 'All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment'. There are no detailed plans for reducing the impact of traffic from the North of Baldock site (BA1) on the A507/A505 Junction, except for a mini-roundabout and phased lights. The Station Road/North Road Railway bridge on the busy A507 is already being regularly damaged by the volume of heavy goods traffic, and the impact of more cars/pedestrians has not been fully assessed. The road under the bridge cannot be widened to accommodate the increase in traffic. There are two very narrow pedestrian ways under the bridge that cannot be widened to accommodate the increase in pedestrians walking to the station from the BA1 site. Pedestrians would be put at risk when using the two narrow footpaths under the bridge, indeed there have been pedestrians injured (including children) trying to use these footpaths in recent years.
The A1 is becoming significantly more congested due to a large number of houses that are being built in Biggleswade (which is just 8 miles north of Baldock on the AI). The addition of the proposed 7000 vehicles from Baldock would add to this congestion causing North Herts to become gridlocked during peak times.
At least a second rail crossing and a link road would have to be an essential part of a local plan. The plan mentions that the proposed site will need a new link road, including an additional bridge over the railway so that not all traffic has to use the Station Road/North Road bridge and A505/A507 Junction with its vulnerable historic buildings. However, the local sustainability transport assessment does not consider North Baldock in the traffic modeling, and local Plan Model Testing 60271338 states that Baldock and Letchworth have not been tested to date. Local Plan SP14 4.180 says safe access will be needed to the north of Baldock but doesn't say how it will be achieved. There is also mention of Southern link road in B3 and B4 but no details are given. The Plan is not effective as it cannot be delivered in the plan period. It also fails consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work. Road links to the east and west are wholly inadequate and links north and south are already severely congested particularly at peak times. The local plan makes no mention of improvements to these road links. The mini-roundabout is the only cost included in the plan for Baldock despite the clear need for major transport projects, such as a new crossing with the railway and major roadways that would be required to divert at least some of the extra 7000 vehicles away from the A505/A507 junction.
There are severe doubts over the capacity for the railway to take a potential doubling of passengers (from new housing development) at Baldock train station. Commuters from the new development BA1 will require quick, safe and efficient access to the station. NPPF Paragraph 32 states that safe and suitable access to the site should be provided for all transport users. The railway station itself will need to be enhanced with additional services and facilities. Govia, the train service provider, is conducting its own consultation about changes to timetabling and new services starting in 2018 but there had been no communication up until November 2016 between NHDC and Govia relating to the proposed Local plan. The plan makes no significant points other than the convenience of location near to a station. NHDC has not consulted with Govia during the course of the preparation of this local plan. Currently, Govia is planning to reduce the service to Baldock at off-peak times. NPPF Paragraph 32 goes on to state that development decisions should take account of whether improvements can be undertaken within the existing transport network. NPPF paragraph 32 states that all developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. The Local Plan is therefore not effective as it cannot be delivered in the plan period. It also fails the national policy test as it does not properly assess the required transport improvements.

SP7 Infrastructure requirements and developer contribution
There are doubts over the provision of schools, health and recreational facilities and when they will be provided. Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered 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. The local plan 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.

SP12 Green infrastructure, biodiversity and landscape
Ivel Nature Reserve Baldock as a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is valued by locals and benefits greatly from the surrounding farmland. The 1979 Act (Scheduled Ancient Monuments) emphasises the need for care with planning consent in these instances. In addition, the BA1 site is designated as being of archaeological interest and is consequently subject to additional planning requirements.
In the Local Plan, sustainability appraisal notes identify BA1 to have moderate to high landscape sensitivity. NPPF 118 states: When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused; proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made if the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest. Local people are extremely concerned that this has not been adequately addressed in the local plan.

SP13 Historic environment
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. The historic market town of Baldock cannot sustain the proposed 80% growth; the unique character of the town would be lost for ever. It is very possible that Baldock is likely to become two towns with limited integration of social and economic communities. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive communities. Local Plan Paragraph 4.38 states that the District contains a range of retail and service centres, from medium sized towns to small village and neighbourhood centres. Each one performs a particular role to meet the needs of its catchment population, and is part of a network of centres within the District, and the Council is committed to protect the vitality and viability of all centres. Paragraph 4.44 notes that the growth of the District will require additional centres to be provided to serve BA1 and the large developments at Baldock. This will require more than just a large housing estate. Moreover, NPPF Paragraph 126 states that local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account: the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; the desirability of new development making a positive contribution to local character and distinctiveness; and opportunities to draw on the contribution made by the historic environment to the character of a place. In this regard increasing the size of Baldock by 80% (3,500 houses) will put its significant heritage assets at great risk.

SP14 Site BA1 North of Baldock
There are doubts over the provision of schools, health and recreational facilities and when they will be provided. Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered 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. The local plan 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.
Ivel Nature Reserve a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is well greatly valued by locals and benefits greatly from the surrounding farmland.
The BA1 site is Green Belt to the north of Baldock. It has been designated Green Belt to protect the northern boundary of the town and to preserve the setting and special character of the historic town of Baldock. The BA1 site is very well established quality and accessible agricultural land that has been devotedly farmed for many decades. If the BA1 site goes ahead this prime agricultural land will be lost for ever. There are many small holdings that will lose their land which has been handed down from generation to generation. Small farmers will lose their livelihood. There are doubts over whether adequate consideration has been given to available brownfield sites before building on Green Belt. The BA1 North Baldock housing site has been designated purely on the basis that it is land currently owned by Hertfordshire County Council and therefore cheaply and easily acquired. There is no evidence to show that other sites were considered, and there is no assessment to show that this is the most suitable site for a development of this size. No other consideration has been given to justifying why the site north of Baldock is the best one available. Furthermore, the planned development at Baldock is vastly disproportionate to that which is planned for Letchworth and Hitchin, which are both significantly larger towns. Other land owners are prepared to put their land forward for development, however they have not been considered.

D4 Air Quality
Baldock is located in a bowl in the lee of the low lying Chiltern chalk hills, where pollution nests and can lead to health problems such as asthma and other breathing problems. It is essential that an assessment is carried out on the pollution impact of the extra 7000 vehicles that will pass through Baldock. Also, particulates from tyres and brakes cause pollution making roundabouts particularly bad. Notably, in paragraph 9.28, the plan notes that air quality standards are already close to being exceeded in Whitehorse Street and Hitchin Street in Baldock. The Housing and Green Belt Background paper notes that former site 209E (Priory Fields in Hitchin) was considered unsuitable for building on for the same reason. NPPF Paragraph 124 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, as it fails the criteria in that it is not consistent with national policy on air quality limits.

SP4 Town and Local Centres
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. The historic market town of Baldock cannot sustain the proposed 80% growth; the unique character of the town would be lost for ever. It is very possible that Baldock is likely to become two towns with limited integration of social and economic communities. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive communities. Local Plan Paragraph 4.38 states that the District contains a range of retail and service centres, from medium sized towns to small village and neighbourhood centres. Each one performs a particular role to meet the needs of its catchment population, and is part of a network of centres within the District, and the Council is committed to protect the vitality and viability of all centres. Paragraph 4.44 notes that the growth of the District will require additional centres to be provided to serve BA1 and the large developments at Baldock. This will require more than just a large housing estate. Moreover, NPPF Paragraph 126 states that local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account: the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; the desirability of new development making a positive contribution to local character and distinctiveness; and opportunities to draw on the contribution made by the historic environment to the character of a place. In this regard increasing the size of Baldock by 80% (3,500 houses) will put its significant heritage assets at great risk.

NE1 Landscape
Ivel Nature Reserve a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is valued by locals and benefits greatly from the surrounding farmland. The 1979 Act (Scheduled Ancient Monuments) emphasises the need for care with planning consent in these instances. In addition, the BA1 site is designated as being of archaeological interest and is consequently subject to additional planning requirements.
In the Local Plan, sustainability appraisal notes identify BA1 to have moderate to high landscape sensitivity. NPPF 118 states: When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused; proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made if the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest. Local people are extremely concerned that this has not been adequately addressed in the local plan.

NE8 Sustainable drainage systems
Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable.

NE9 Water Quality and environment
Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered 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. The local plan is not consistent with national policy as it has not assessed the costs of providing the necessary infrastructure at Baldock and assumes that costs will be met by developers.

SP5 Countryside and Green Belt
The BA1 site is Green Belt to the north of Baldock. It has been designated Green Belt to protect the northern boundary of the town and to preserve the setting and special character of the historic town of Baldock. The BA1 site is very well established quality and accessible agricultural land that has been devotedly farmed for many decades. If the BA1 site goes ahead this prime agricultural land will be lost for ever. There are many small holdings that will lose their land which has been handed down from generation to generation. Small farmers will lose their livelihood. There are doubts over whether adequate consideration has been given to available brownfield sites before building on Green Belt. Contrary to the NPPF paragraph 80 point 4, which lists one of the main purposes of the Green Belt is to preserve the setting and special character of historic towns like Baldock (the oldest historic town in North Hertfordshire), the local plan, paragraph 5.52 justifies removing BA1 from the Green Belt on the basis that it can contribute to meeting housing requirements in the first five years following adoption of the plan. This is contradicted in the Local Plan itself as the site will only be developed after the smaller sites across the town. This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. NPPF paragraph 82 states: The general extent of Green Belts across the country is already established. New Green Belts should only be established in exceptional circumstances, for example when planning for larger scale development such as new settlements or major urban extensions. I do not believe that this is an exceptional circumstance. The BA1 North Baldock housing site has been designated purely on the basis that it is land currently owned by Hertfordshire County Council and therefore cheaply and easily acquired. There is no evidence to show that other sites were considered, and there is no assessment to show that this is the most suitable site for a development of this size. No other consideration has been given to justifying why the site north of Baldock is the best one available. Furthermore, the planned development at Baldock is vastly disproportionate to that which is planned for Letchworth and Hitchin, which are both significantly larger towns. Other land owners are prepared to put their land forward for development, however they have not been considered.

I wish to object to the North Hertfordshire Local Plan 2011-2031 for the reasons I have stated above. I do not consider it a sound plan for the future of Baldock..

I am writing in response to the proposed Local Plan for Baldock in North Hertfordshire. I have presented my response below by referring to the National Planning Policy Framework and the Local Plan.

SP6 Sustainable Transport
With regard to the BA1 North of Baldock site, traffic congestion on the A507 has always been an enormous problem and it has been exacerbated since the opening of the Baldock by-pass in 2006. Increased traffic on the A507 from the BA1 site would encourage vehicles to use the single track Nortonbury Lane to access the town and severely compromise the safety and nature of this lane. A further concern is the dangerous double bend on the A507 at Mill Valley (that often becomes flooded in heavy rains) which would put at risk traffic and pedestrians using any proposed access road onto the BA1 site. The town has been described as an hourglass, with the crossroads of A505 and A507 at the pinch point, its centre. The listed buildings (dating back to the 1500s) at the junction make finding a solution virtually impossible. There are already tailbacks from this junction back along the A507, bordering the site where the BA1 North of Baldock site is planned. This occurs at most times of the day and particularly during morning and evening peak times. This has also been exacerbated by Sat Nav companies guiding lorries and other traffic along the A507 and through this junction. The traffic will increase by approximately 7000 cars generated from the new housing development as well as any additional commercial traffic. I attach photos taken on two consecutive days showing typical traffic jams stretching back along the A507 (from the junction with the A505). These are taken where the A507 borders the proposed BA1 north of Baldock site. All the town's amenities are at the other side of the town to the BA1 development and this will mean that cars will have to cross the very congested A505/A507 junction and add to the already heavy congestion to get to the town centre. NPPF Section 4 'Promoting Sustainable Transport' paragraph 32, states that 'All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment'. There are no detailed plans for reducing the impact of traffic from the North of Baldock site (BA1) on the A507/A505 Junction, except for a mini-roundabout and phased lights. The Station Road/North Road Railway bridge on the busy A507 is already being regularly damaged by the volume of heavy goods traffic, and the impact of more cars/pedestrians has not been fully assessed. The road under the bridge cannot be widened to accommodate the increase in traffic. There are two very narrow pedestrian ways under the bridge that cannot be widened to accommodate the increase in pedestrians walking to the station from the BA1 site. Pedestrians would be put at risk when using the two narrow footpaths under the bridge, indeed there have been pedestrians injured (including children) trying to use these footpaths in recent years.
The A1 is becoming significantly more congested due to a large number of houses that are being built in Biggleswade (which is just 8 miles north of Baldock on the AI). The addition of the proposed 7000 vehicles from Baldock would add to this congestion causing North Herts to become gridlocked during peak times.
At least a second rail crossing and a link road would have to be an essential part of a local plan. The plan mentions that the proposed site will need a new link road, including an additional bridge over the railway so that not all traffic has to use the Station Road/North Road bridge and A505/A507 Junction with its vulnerable historic buildings. However, the local sustainability transport assessment does not consider North Baldock in the traffic modeling, and local Plan Model Testing 60271338 states that Baldock and Letchworth have not been tested to date. Local Plan SP14 4.180 says safe access will be needed to the north of Baldock but doesn't say how it will be achieved. There is also mention of Southern link road in B3 and B4 but no details are given. The Plan is not effective as it cannot be delivered in the plan period. It also fails consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work. Road links to the east and west are wholly inadequate and links north and south are already severely congested particularly at peak times. The local plan makes no mention of improvements to these road links. The mini-roundabout is the only cost included in the plan for Baldock despite the clear need for major transport projects, such as a new crossing with the railway and major roadways that would be required to divert at least some of the extra 7000 vehicles away from the A505/A507 junction.
There are severe doubts over the capacity for the railway to take a potential doubling of passengers (from new housing development) at Baldock train station. Commuters from the new development BA1 will require quick, safe and efficient access to the station. NPPF Paragraph 32 states that safe and suitable access to the site should be provided for all transport users. The railway station itself will need to be enhanced with additional services and facilities. Govia, the train service provider, is conducting its own consultation about changes to timetabling and new services starting in 2018 but there had been no communication up until November 2016 between NHDC and Govia relating to the proposed Local plan. The plan makes no significant points other than the convenience of location near to a station. NHDC has not consulted with Govia during the course of the preparation of this local plan. Currently, Govia is planning to reduce the service to Baldock at off-peak times. NPPF Paragraph 32 goes on to state that development decisions should take account of whether improvements can be undertaken within the existing transport network. NPPF paragraph 32 states that all developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. The Local Plan is therefore not effective as it cannot be delivered in the plan period. It also fails the national policy test as it does not properly assess the required transport improvements.

SP7 Infrastructure requirements and developer contribution
There are doubts over the provision of schools, health and recreational facilities and when they will be provided. Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered 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. The local plan 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.

SP12 Green infrastructure, biodiversity and landscape
Ivel Nature Reserve Baldock as a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is valued by locals and benefits greatly from the surrounding farmland. The 1979 Act (Scheduled Ancient Monuments) emphasises the need for care with planning consent in these instances. In addition, the BA1 site is designated as being of archaeological interest and is consequently subject to additional planning requirements.
In the Local Plan, sustainability appraisal notes identify BA1 to have moderate to high landscape sensitivity. NPPF 118 states: When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused; proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made if the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest. Local people are extremely concerned that this has not been adequately addressed in the local plan.

SP13 Historic environment
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. The historic market town of Baldock cannot sustain the proposed 80% growth; the unique character of the town would be lost for ever. It is very possible that Baldock is likely to become two towns with limited integration of social and economic communities. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive communities. Local Plan Paragraph 4.38 states that the District contains a range of retail and service centres, from medium sized towns to small village and neighbourhood centres. Each one performs a particular role to meet the needs of its catchment population, and is part of a network of centres within the District, and the Council is committed to protect the vitality and viability of all centres. Paragraph 4.44 notes that the growth of the District will require additional centres to be provided to serve BA1 and the large developments at Baldock. This will require more than just a large housing estate. Moreover, NPPF Paragraph 126 states that local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account: the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; the desirability of new development making a positive contribution to local character and distinctiveness; and opportunities to draw on the contribution made by the historic environment to the character of a place. In this regard increasing the size of Baldock by 80% (3,500 houses) will put its significant heritage assets at great risk.

SP14 Site BA1 North of Baldock
There are doubts over the provision of schools, health and recreational facilities and when they will be provided. Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered 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. The local plan 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.
Ivel Nature Reserve a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is well greatly valued by locals and benefits greatly from the surrounding farmland.
The BA1 site is Green Belt to the north of Baldock. It has been designated Green Belt to protect the northern boundary of the town and to preserve the setting and special character of the historic town of Baldock. The BA1 site is very well established quality and accessible agricultural land that has been devotedly farmed for many decades. If the BA1 site goes ahead this prime agricultural land will be lost for ever. There are many small holdings that will lose their land which has been handed down from generation to generation. Small farmers will lose their livelihood. There are doubts over whether adequate consideration has been given to available brownfield sites before building on Green Belt. The BA1 North Baldock housing site has been designated purely on the basis that it is land currently owned by Hertfordshire County Council and therefore cheaply and easily acquired. There is no evidence to show that other sites were considered, and there is no assessment to show that this is the most suitable site for a development of this size. No other consideration has been given to justifying why the site north of Baldock is the best one available. Furthermore, the planned development at Baldock is vastly disproportionate to that which is planned for Letchworth and Hitchin, which are both significantly larger towns. Other land owners are prepared to put their land forward for development, however they have not been considered.

D4 Air Quality
Baldock is located in a bowl in the lee of the low lying Chiltern chalk hills, where pollution nests and can lead to health problems such as asthma and other breathing problems. It is essential that an assessment is carried out on the pollution impact of the extra 7000 vehicles that will pass through Baldock. Also, particulates from tyres and brakes cause pollution making roundabouts particularly bad. Notably, in paragraph 9.28, the plan notes that air quality standards are already close to being exceeded in Whitehorse Street and Hitchin Street in Baldock. The Housing and Green Belt Background paper notes that former site 209E (Priory Fields in Hitchin) was considered unsuitable for building on for the same reason. NPPF Paragraph 124 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, as it fails the criteria in that it is not consistent with national policy on air quality limits.

SP4 Town and Local Centres
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. The historic market town of Baldock cannot sustain the proposed 80% growth; the unique character of the town would be lost for ever. It is very possible that Baldock is likely to become two towns with limited integration of social and economic communities. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive communities. Local Plan Paragraph 4.38 states that the District contains a range of retail and service centres, from medium sized towns to small village and neighbourhood centres. Each one performs a particular role to meet the needs of its catchment population, and is part of a network of centres within the District, and the Council is committed to protect the vitality and viability of all centres. Paragraph 4.44 notes that the growth of the District will require additional centres to be provided to serve BA1 and the large developments at Baldock. This will require more than just a large housing estate. Moreover, NPPF Paragraph 126 states that local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account: the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; the desirability of new development making a positive contribution to local character and distinctiveness; and opportunities to draw on the contribution made by the historic environment to the character of a place. In this regard increasing the size of Baldock by 80% (3,500 houses) will put its significant heritage assets at great risk.

NE1 Landscape
Ivel Nature Reserve a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is valued by locals and benefits greatly from the surrounding farmland. The 1979 Act (Scheduled Ancient Monuments) emphasises the need for care with planning consent in these instances. In addition, the BA1 site is designated as being of archaeological interest and is consequently subject to additional planning requirements.
In the Local Plan, sustainability appraisal notes identify BA1 to have moderate to high landscape sensitivity. NPPF 118 states: When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused; proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made if the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest. Local people are extremely concerned that this has not been adequately addressed in the local plan.

NE8 Sustainable drainage systems
Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable.

NE9 Water Quality and environment
Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered 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. The local plan is not consistent with national policy as it has not assessed the costs of providing the necessary infrastructure at Baldock and assumes that costs will be met by developers.

SP5 Countryside and Green Belt
The BA1 site is Green Belt to the north of Baldock. It has been designated Green Belt to protect the northern boundary of the town and to preserve the setting and special character of the historic town of Baldock. The BA1 site is very well established quality and accessible agricultural land that has been devotedly farmed for many decades. If the BA1 site goes ahead this prime agricultural land will be lost for ever. There are many small holdings that will lose their land which has been handed down from generation to generation. Small farmers will lose their livelihood. There are doubts over whether adequate consideration has been given to available brownfield sites before building on Green Belt. Contrary to the NPPF paragraph 80 point 4, which lists one of the main purposes of the Green Belt is to preserve the setting and special character of historic towns like Baldock (the oldest historic town in North Hertfordshire), the local plan, paragraph 5.52 justifies removing BA1 from the Green Belt on the basis that it can contribute to meeting housing requirements in the first five years following adoption of the plan. This is contradicted in the Local Plan itself as the site will only be developed after the smaller sites across the town. This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. NPPF paragraph 82 states: The general extent of Green Belts across the country is already established. New Green Belts should only be established in exceptional circumstances, for example when planning for larger scale development such as new settlements or major urban extensions. I do not believe that this is an exceptional circumstance. The BA1 North Baldock housing site has been designated purely on the basis that it is land currently owned by Hertfordshire County Council and therefore cheaply and easily acquired. There is no evidence to show that other sites were considered, and there is no assessment to show that this is the most suitable site for a development of this size. No other consideration has been given to justifying why the site north of Baldock is the best one available. Furthermore, the planned development at Baldock is vastly disproportionate to that which is planned for Letchworth and Hitchin, which are both significantly larger towns. Other land owners are prepared to put their land forward for development, however they have not been considered.

I wish to object to the North Hertfordshire Local Plan 2011-2031 for the reasons I have stated above. I do not consider it a sound plan for the future of Baldock..

I am writing in response to the proposed Local Plan for Baldock in North Hertfordshire. I have presented my response below by referring to the National Planning Policy Framework and the Local Plan.

SP6 Sustainable Transport
With regard to the BA1 North of Baldock site, traffic congestion on the A507 has always been an enormous problem and it has been exacerbated since the opening of the Baldock by-pass in 2006. Increased traffic on the A507 from the BA1 site would encourage vehicles to use the single track Nortonbury Lane to access the town and severely compromise the safety and nature of this lane. A further concern is the dangerous double bend on the A507 at Mill Valley (that often becomes flooded in heavy rains) which would put at risk traffic and pedestrians using any proposed access road onto the BA1 site. The town has been described as an hourglass, with the crossroads of A505 and A507 at the pinch point, its centre. The listed buildings (dating back to the 1500s) at the junction make finding a solution virtually impossible. There are already tailbacks from this junction back along the A507, bordering the site where the BA1 North of Baldock site is planned. This occurs at most times of the day and particularly during morning and evening peak times. This has also been exacerbated by Sat Nav companies guiding lorries and other traffic along the A507 and through this junction. The traffic will increase by approximately 7000 cars generated from the new housing development as well as any additional commercial traffic. I attach photos taken on two consecutive days showing typical traffic jams stretching back along the A507 (from the junction with the A505). These are taken where the A507 borders the proposed BA1 north of Baldock site. All the town's amenities are at the other side of the town to the BA1 development and this will mean that cars will have to cross the very congested A505/A507 junction and add to the already heavy congestion to get to the town centre. NPPF Section 4 'Promoting Sustainable Transport' paragraph 32, states that 'All developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment'. There are no detailed plans for reducing the impact of traffic from the North of Baldock site (BA1) on the A507/A505 Junction, except for a mini-roundabout and phased lights. The Station Road/North Road Railway bridge on the busy A507 is already being regularly damaged by the volume of heavy goods traffic, and the impact of more cars/pedestrians has not been fully assessed. The road under the bridge cannot be widened to accommodate the increase in traffic. There are two very narrow pedestrian ways under the bridge that cannot be widened to accommodate the increase in pedestrians walking to the station from the BA1 site. Pedestrians would be put at risk when using the two narrow footpaths under the bridge, indeed there have been pedestrians injured (including children) trying to use these footpaths in recent years.
The A1 is becoming significantly more congested due to a large number of houses that are being built in Biggleswade (which is just 8 miles north of Baldock on the AI). The addition of the proposed 7000 vehicles from Baldock would add to this congestion causing North Herts to become gridlocked during peak times.
At least a second rail crossing and a link road would have to be an essential part of a local plan. The plan mentions that the proposed site will need a new link road, including an additional bridge over the railway so that not all traffic has to use the Station Road/North Road bridge and A505/A507 Junction with its vulnerable historic buildings. However, the local sustainability transport assessment does not consider North Baldock in the traffic modeling, and local Plan Model Testing 60271338 states that Baldock and Letchworth have not been tested to date. Local Plan SP14 4.180 says safe access will be needed to the north of Baldock but doesn't say how it will be achieved. There is also mention of Southern link road in B3 and B4 but no details are given. The Plan is not effective as it cannot be delivered in the plan period. It also fails consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work. Road links to the east and west are wholly inadequate and links north and south are already severely congested particularly at peak times. The local plan makes no mention of improvements to these road links. The mini-roundabout is the only cost included in the plan for Baldock despite the clear need for major transport projects, such as a new crossing with the railway and major roadways that would be required to divert at least some of the extra 7000 vehicles away from the A505/A507 junction.
There are severe doubts over the capacity for the railway to take a potential doubling of passengers (from new housing development) at Baldock train station. Commuters from the new development BA1 will require quick, safe and efficient access to the station. NPPF Paragraph 32 states that safe and suitable access to the site should be provided for all transport users. The railway station itself will need to be enhanced with additional services and facilities. Govia, the train service provider, is conducting its own consultation about changes to timetabling and new services starting in 2018 but there had been no communication up until November 2016 between NHDC and Govia relating to the proposed Local plan. The plan makes no significant points other than the convenience of location near to a station. NHDC has not consulted with Govia during the course of the preparation of this local plan. Currently, Govia is planning to reduce the service to Baldock at off-peak times. NPPF Paragraph 32 goes on to state that development decisions should take account of whether improvements can be undertaken within the existing transport network. NPPF paragraph 32 states that all developments that generate significant amounts of movement should be supported by a Transport Statement or Transport Assessment. The Local Plan is therefore not effective as it cannot be delivered in the plan period. It also fails the national policy test as it does not properly assess the required transport improvements.

SP7 Infrastructure requirements and developer contribution
There are doubts over the provision of schools, health and recreational facilities and when they will be provided. Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered 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. The local plan 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.

SP12 Green infrastructure, biodiversity and landscape
Ivel Nature Reserve Baldock as a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is valued by locals and benefits greatly from the surrounding farmland. The 1979 Act (Scheduled Ancient Monuments) emphasises the need for care with planning consent in these instances. In addition, the BA1 site is designated as being of archaeological interest and is consequently subject to additional planning requirements.
In the Local Plan, sustainability appraisal notes identify BA1 to have moderate to high landscape sensitivity. NPPF 118 states: When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused; proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made if the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest. Local people are extremely concerned that this has not been adequately addressed in the local plan.

SP13 Historic environment
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. The historic market town of Baldock cannot sustain the proposed 80% growth; the unique character of the town would be lost for ever. It is very possible that Baldock is likely to become two towns with limited integration of social and economic communities. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive communities. Local Plan Paragraph 4.38 states that the District contains a range of retail and service centres, from medium sized towns to small village and neighbourhood centres. Each one performs a particular role to meet the needs of its catchment population, and is part of a network of centres within the District, and the Council is committed to protect the vitality and viability of all centres. Paragraph 4.44 notes that the growth of the District will require additional centres to be provided to serve BA1 and the large developments at Baldock. This will require more than just a large housing estate. Moreover, NPPF Paragraph 126 states that local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account: the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; the desirability of new development making a positive contribution to local character and distinctiveness; and opportunities to draw on the contribution made by the historic environment to the character of a place. In this regard increasing the size of Baldock by 80% (3,500 houses) will put its significant heritage assets at great risk.

SP14 Site BA1 North of Baldock
There are doubts over the provision of schools, health and recreational facilities and when they will be provided. Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered 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. The local plan 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.
Ivel Nature Reserve a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is well greatly valued by locals and benefits greatly from the surrounding farmland.
The BA1 site is Green Belt to the north of Baldock. It has been designated Green Belt to protect the northern boundary of the town and to preserve the setting and special character of the historic town of Baldock. The BA1 site is very well established quality and accessible agricultural land that has been devotedly farmed for many decades. If the BA1 site goes ahead this prime agricultural land will be lost for ever. There are many small holdings that will lose their land which has been handed down from generation to generation. Small farmers will lose their livelihood. There are doubts over whether adequate consideration has been given to available brownfield sites before building on Green Belt. The BA1 North Baldock housing site has been designated purely on the basis that it is land currently owned by Hertfordshire County Council and therefore cheaply and easily acquired. There is no evidence to show that other sites were considered, and there is no assessment to show that this is the most suitable site for a development of this size. No other consideration has been given to justifying why the site north of Baldock is the best one available. Furthermore, the planned development at Baldock is vastly disproportionate to that which is planned for Letchworth and Hitchin, which are both significantly larger towns. Other land owners are prepared to put their land forward for development, however they have not been considered.

D4 Air Quality
Baldock is located in a bowl in the lee of the low lying Chiltern chalk hills, where pollution nests and can lead to health problems such as asthma and other breathing problems. It is essential that an assessment is carried out on the pollution impact of the extra 7000 vehicles that will pass through Baldock. Also, particulates from tyres and brakes cause pollution making roundabouts particularly bad. Notably, in paragraph 9.28, the plan notes that air quality standards are already close to being exceeded in Whitehorse Street and Hitchin Street in Baldock. The Housing and Green Belt Background paper notes that former site 209E (Priory Fields in Hitchin) was considered unsuitable for building on for the same reason. NPPF Paragraph 124 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, as it fails the criteria in that it is not consistent with national policy on air quality limits.

SP4 Town and Local Centres
Baldock is the oldest and most historic town in North Hertfordshire. The historic town centre and the cultural aspects of Baldock should be protected. The historic market town of Baldock cannot sustain the proposed 80% growth; the unique character of the town would be lost for ever. It is very possible that Baldock is likely to become two towns with limited integration of social and economic communities. NPPF Paragraph 69 states that the planning system should play an important role in facilitating social interaction and creating healthy, inclusive communities. Local Plan Paragraph 4.38 states that the District contains a range of retail and service centres, from medium sized towns to small village and neighbourhood centres. Each one performs a particular role to meet the needs of its catchment population, and is part of a network of centres within the District, and the Council is committed to protect the vitality and viability of all centres. Paragraph 4.44 notes that the growth of the District will require additional centres to be provided to serve BA1 and the large developments at Baldock. This will require more than just a large housing estate. Moreover, NPPF Paragraph 126 states that local planning authorities should set out in their Local Plan a positive strategy for the conservation and enjoyment of the historic environment, including heritage assets most at risk through neglect, decay or other threats. In doing so, they should recognise that heritage assets are an irreplaceable resource and conserve them in a manner appropriate to their significance. In developing this strategy, local planning authorities should take into account: the desirability of sustaining and enhancing the significance of heritage assets and putting them to viable uses consistent with their conservation; the wider social, cultural, economic and environmental benefits that conservation of the historic environment can bring; the desirability of new development making a positive contribution to local character and distinctiveness; and opportunities to draw on the contribution made by the historic environment to the character of a place. In this regard increasing the size of Baldock by 80% (3,500 houses) will put its significant heritage assets at great risk.

NE1 Landscape
Ivel Nature Reserve a Site of Special Scientific Interest and a Scheduled Ancient Monument needs protection and the siting of BA1 a very large housing development adjacent to this site will threaten the sensitive nature of its vulnerable biodiversity. There will be a significant detrimental impact on this ecologically sensitive area and local wildlife due to the loss of a very large area of open space which is essential for the survival of the rare breads of bats, newts and the corn bunting which exist there. The site has a history stretching back more than 5000 years, it is valued by locals and benefits greatly from the surrounding farmland. The 1979 Act (Scheduled Ancient Monuments) emphasises the need for care with planning consent in these instances. In addition, the BA1 site is designated as being of archaeological interest and is consequently subject to additional planning requirements.
In the Local Plan, sustainability appraisal notes identify BA1 to have moderate to high landscape sensitivity. NPPF 118 states: When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles: if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused; proposed development on land within or outside a Site of Special Scientific Interest likely to have an adverse effect on a Site of Special Scientific Interest (either individually or in combination with other developments) should not normally be permitted. Where an adverse effect on the site's notified special interest features is likely, an exception should only be made if the benefits of the development, at this site, clearly outweigh both the impacts that it is likely to have on the features of the site that make it of special scientific interest and any broader impacts on the national network of Sites of Special Scientific Interest. Local people are extremely concerned that this has not been adequately addressed in the local plan.

NE8 Sustainable drainage systems
Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable.

NE9 Water Quality and environment
Baldock already struggles to cope with sewage waste; the impact of a further 3,500 dwellings will create a sewage problem that will be insurmountable. SP14 states that a masterplan must be produced prior to any other detailed matters, however no detailed plans have been given. There is an Infrastructure development plan included in the evidence base (added September 2016) but it does not give detailed plans. NPPF paragraph 177 states that it is equally important that planned infrastructure be delivered 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. The local plan is not consistent with national policy as it has not assessed the costs of providing the necessary infrastructure at Baldock and assumes that costs will be met by developers.

SP5 Countryside and Green Belt
The BA1 site is Green Belt to the north of Baldock. It has been designated Green Belt to protect the northern boundary of the town and to preserve the setting and special character of the historic town of Baldock. The BA1 site is very well established quality and accessible agricultural land that has been devotedly farmed for many decades. If the BA1 site goes ahead this prime agricultural land will be lost for ever. There are many small holdings that will lose their land which has been handed down from generation to generation. Small farmers will lose their livelihood. There are doubts over whether adequate consideration has been given to available brownfield sites before building on Green Belt. Contrary to the NPPF paragraph 80 point 4, which lists one of the main purposes of the Green Belt is to preserve the setting and special character of historic towns like Baldock (the oldest historic town in North Hertfordshire), the local plan, paragraph 5.52 justifies removing BA1 from the Green Belt on the basis that it can contribute to meeting housing requirements in the first five years following adoption of the plan. This is contradicted in the Local Plan itself as the site will only be developed after the smaller sites across the town. This plan cannot be justified as being the most appropriate strategy, when considered against the reasonable alternatives. NPPF paragraph 82 states: The general extent of Green Belts across the country is already established. New Green Belts should only be established in exceptional circumstances, for example when planning for larger scale development such as new settlements or major urban extensions. I do not believe that this is an exceptional circumstance. The BA1 North Baldock housing site has been designated purely on the basis that it is land currently owned by Hertfordshire County Council and therefore cheaply and easily acquired. There is no evidence to show that other sites were considered, and there is no assessment to show that this is the most suitable site for a development of this size. No other consideration has been given to justifying why the site north of Baldock is the best one available. Furthermore, the planned development at Baldock is vastly disproportionate to that which is planned for Letchworth and Hitchin, which are both significantly larger towns. Other land owners are prepared to put their land forward for development, however they have not been considered.

I wish to object to the North Hertfordshire Local Plan 2011-2031 for the reasons I have stated above. I do not consider it a sound plan for the future of Baldock..