Local Plan 2011-2031 Proposed Submission Draft

I wish to make the following representations in response to the Submission Draft Local Plan.

The whole plan is "unsound" because it is fundamentally flawed in a number of ways:
* The supposedly objective assessment of housing need is based simply on projections produced by the Office of National Statistics. No attempt has been made to validate these against past trends. In fact they would require that houses are built in North Herts at a greater rate than has ever happened in the past. Since the plan is for the period from 2011 to 2031 a quarter of the plan period has already happened. During that time the rate of development has been less than half that projected for the plan period as a whole.
* The housing target has not been influenced by the need to limit or avoid building on green belt land. The government has said that assessed need does not, on its own, represent a case for building on green belt land, but that is exactly what the plan argues.
* The mechanism that has been used for identifying sites is flawed. The Council simply asked land owners or developers to suggest sites that they would like to develop (at least one major site has been put forward by a developer who does not own the site concerned). There has been no attempt to identify sites that would be suitable for meeting housing need whilst meeting community and sustainability requirements. The result is that housing is proposed in the locations that suit the developers rather than those that provide the best solution for the community.
* The plan includes inadequate provisions to would ensure that brown field sites will be developed first with green field and green belt sites only following later if the demand is shown to exist.
* The traffic impact assessment is totally inadequate. The plan relies on an assessment that covers Stevenage, Hitchin and most of Letchworth and Baldock, together with another that covers Royston. The largest development proposed at Baldock is beyond the edge of the area covered by the traffic model. In addition whilst the effects of Stevenage and Welwyn Hatfield are considered, Central Bedfordshire and the proposed developments there are completely ignored. The supporting report sets an absurdly high threshold for congestion, only regarding junctions as congested if they will have "more than 100" vehicles queuing at the end of the peak hour. The proposed mitigation measures fail to identify the extent to which the problem will be improved and the proposals appear to take no account of traffic diversion to rural or residential roads.
The second level of objection is to the flaws in the proposals for individual sites:
1. GA2 - Tilekiln
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For most of its length if follows a footpath or a poorly defined field boundary. The strange shape of the site relates to land ownership rather than any natural feature and demonstrated that this is not a suitable boundary.
* Access to the site from Great Ashby is restricted to a narrow path through a wood land beneath powerlines.
* The site is proposed as the location for a school, but placing a school right on the edge of a settlement in this way will ensure that many children are brought by car.
* The development will clearly relate to Stevenage (despite being in North Herts) yet is remote from any of the town's facilities and will encourage longer car journeys to shops, secondary schools and leisure facilities.
2. GA1 - Roundwood
* Access to the site is unsatisfactory, requiring measures to prevent parking on roads in Great Ashby that are outside the site.
3. NS1 - North Stevenage
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For much of its length it is in the middle of a field.
* The site will clearly result in coalescence of Graveley with Stevenage. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* In addition it appears that access issues may not have been adequately considered.
4. WE1 - Weston
* Access to the Hitchin Road site needs to be from Hitchin Road and not from The Snipe.
*There is no pavement along a section of Hitchin Road that residents in the new development would need to use to get to the school, the shop and other village facilities. Any development here should require this to be addressed.
5. BA1 - Baldock
* The traffic assessments do not identify what would be required to make the large site north east of Baldock achievable.
* The land is admitted to "make a significant contribution to the Green Belt purposes".
* The site will clearly result in coalescence of Bygrave with Baldock. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* The National Planning Policy Framework requires that, for proposals of this sort, infrastructure should be planned at the same time as the Local Plan is prepared but there are no details of this in the plan.
* If built the proposed road linking the A505 with the A507 north of Baldock would have inevitably see use as a Baldock eastern by pass. Its specification and construction would need to reflect this use which would require placing significant parts of the road in a cutting to avoid unacceptable impacts on both the urban area and the adjacent countryside.

I wish to make the following representations in response to the Submission Draft Local Plan.

The whole plan is "unsound" because it is fundamentally flawed in a number of ways:
* The supposedly objective assessment of housing need is based simply on projections produced by the Office of National Statistics. No attempt has been made to validate these against past trends. In fact they would require that houses are built in North Herts at a greater rate than has ever happened in the past. Since the plan is for the period from 2011 to 2031 a quarter of the plan period has already happened. During that time the rate of development has been less than half that projected for the plan period as a whole.
* The housing target has not been influenced by the need to limit or avoid building on green belt land. The government has said that assessed need does not, on its own, represent a case for building on green belt land, but that is exactly what the plan argues.
* The mechanism that has been used for identifying sites is flawed. The Council simply asked land owners or developers to suggest sites that they would like to develop (at least one major site has been put forward by a developer who does not own the site concerned). There has been no attempt to identify sites that would be suitable for meeting housing need whilst meeting community and sustainability requirements. The result is that housing is proposed in the locations that suit the developers rather than those that provide the best solution for the community.
* The plan includes inadequate provisions to would ensure that brown field sites will be developed first with green field and green belt sites only following later if the demand is shown to exist.
* The traffic impact assessment is totally inadequate. The plan relies on an assessment that covers Stevenage, Hitchin and most of Letchworth and Baldock, together with another that covers Royston. The largest development proposed at Baldock is beyond the edge of the area covered by the traffic model. In addition whilst the effects of Stevenage and Welwyn Hatfield are considered, Central Bedfordshire and the proposed developments there are completely ignored. The supporting report sets an absurdly high threshold for congestion, only regarding junctions as congested if they will have "more than 100" vehicles queuing at the end of the peak hour. The proposed mitigation measures fail to identify the extent to which the problem will be improved and the proposals appear to take no account of traffic diversion to rural or residential roads.
The second level of objection is to the flaws in the proposals for individual sites:
1. GA2 - Tilekiln
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For most of its length if follows a footpath or a poorly defined field boundary. The strange shape of the site relates to land ownership rather than any natural feature and demonstrated that this is not a suitable boundary.
* Access to the site from Great Ashby is restricted to a narrow path through a wood land beneath powerlines.
* The site is proposed as the location for a school, but placing a school right on the edge of a settlement in this way will ensure that many children are brought by car.
* The development will clearly relate to Stevenage (despite being in North Herts) yet is remote from any of the town's facilities and will encourage longer car journeys to shops, secondary schools and leisure facilities.
2. GA1 - Roundwood
* Access to the site is unsatisfactory, requiring measures to prevent parking on roads in Great Ashby that are outside the site.
3. NS1 - North Stevenage
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For much of its length it is in the middle of a field.
* The site will clearly result in coalescence of Graveley with Stevenage. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* In addition it appears that access issues may not have been adequately considered.
4. WE1 - Weston
* Access to the Hitchin Road site needs to be from Hitchin Road and not from The Snipe.
*There is no pavement along a section of Hitchin Road that residents in the new development would need to use to get to the school, the shop and other village facilities. Any development here should require this to be addressed.
5. BA1 - Baldock
* The traffic assessments do not identify what would be required to make the large site north east of Baldock achievable.
* The land is admitted to "make a significant contribution to the Green Belt purposes".
* The site will clearly result in coalescence of Bygrave with Baldock. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* The National Planning Policy Framework requires that, for proposals of this sort, infrastructure should be planned at the same time as the Local Plan is prepared but there are no details of this in the plan.
* If built the proposed road linking the A505 with the A507 north of Baldock would have inevitably see use as a Baldock eastern by pass. Its specification and construction would need to reflect this use which would require placing significant parts of the road in a cutting to avoid unacceptable impacts on both the urban area and the adjacent countryside.

I wish to make the following representations in response to the Submission Draft Local Plan.

The whole plan is "unsound" because it is fundamentally flawed in a number of ways:
* The supposedly objective assessment of housing need is based simply on projections produced by the Office of National Statistics. No attempt has been made to validate these against past trends. In fact they would require that houses are built in North Herts at a greater rate than has ever happened in the past. Since the plan is for the period from 2011 to 2031 a quarter of the plan period has already happened. During that time the rate of development has been less than half that projected for the plan period as a whole.
* The housing target has not been influenced by the need to limit or avoid building on green belt land. The government has said that assessed need does not, on its own, represent a case for building on green belt land, but that is exactly what the plan argues.
* The mechanism that has been used for identifying sites is flawed. The Council simply asked land owners or developers to suggest sites that they would like to develop (at least one major site has been put forward by a developer who does not own the site concerned). There has been no attempt to identify sites that would be suitable for meeting housing need whilst meeting community and sustainability requirements. The result is that housing is proposed in the locations that suit the developers rather than those that provide the best solution for the community.
* The plan includes inadequate provisions to would ensure that brown field sites will be developed first with green field and green belt sites only following later if the demand is shown to exist.
* The traffic impact assessment is totally inadequate. The plan relies on an assessment that covers Stevenage, Hitchin and most of Letchworth and Baldock, together with another that covers Royston. The largest development proposed at Baldock is beyond the edge of the area covered by the traffic model. In addition whilst the effects of Stevenage and Welwyn Hatfield are considered, Central Bedfordshire and the proposed developments there are completely ignored. The supporting report sets an absurdly high threshold for congestion, only regarding junctions as congested if they will have "more than 100" vehicles queuing at the end of the peak hour. The proposed mitigation measures fail to identify the extent to which the problem will be improved and the proposals appear to take no account of traffic diversion to rural or residential roads.
The second level of objection is to the flaws in the proposals for individual sites:
1. GA2 - Tilekiln
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For most of its length if follows a footpath or a poorly defined field boundary. The strange shape of the site relates to land ownership rather than any natural feature and demonstrated that this is not a suitable boundary.
* Access to the site from Great Ashby is restricted to a narrow path through a wood land beneath powerlines.
* The site is proposed as the location for a school, but placing a school right on the edge of a settlement in this way will ensure that many children are brought by car.
* The development will clearly relate to Stevenage (despite being in North Herts) yet is remote from any of the town's facilities and will encourage longer car journeys to shops, secondary schools and leisure facilities.
2. GA1 - Roundwood
* Access to the site is unsatisfactory, requiring measures to prevent parking on roads in Great Ashby that are outside the site.
3. NS1 - North Stevenage
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For much of its length it is in the middle of a field.
* The site will clearly result in coalescence of Graveley with Stevenage. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* In addition it appears that access issues may not have been adequately considered.
4. WE1 - Weston
* Access to the Hitchin Road site needs to be from Hitchin Road and not from The Snipe.
*There is no pavement along a section of Hitchin Road that residents in the new development would need to use to get to the school, the shop and other village facilities. Any development here should require this to be addressed.
5. BA1 - Baldock
* The traffic assessments do not identify what would be required to make the large site north east of Baldock achievable.
* The land is admitted to "make a significant contribution to the Green Belt purposes".
* The site will clearly result in coalescence of Bygrave with Baldock. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* The National Planning Policy Framework requires that, for proposals of this sort, infrastructure should be planned at the same time as the Local Plan is prepared but there are no details of this in the plan.
* If built the proposed road linking the A505 with the A507 north of Baldock would have inevitably see use as a Baldock eastern by pass. Its specification and construction would need to reflect this use which would require placing significant parts of the road in a cutting to avoid unacceptable impacts on both the urban area and the adjacent countryside.

I wish to make the following representations in response to the Submission Draft Local Plan.

The whole plan is "unsound" because it is fundamentally flawed in a number of ways:
* The supposedly objective assessment of housing need is based simply on projections produced by the Office of National Statistics. No attempt has been made to validate these against past trends. In fact they would require that houses are built in North Herts at a greater rate than has ever happened in the past. Since the plan is for the period from 2011 to 2031 a quarter of the plan period has already happened. During that time the rate of development has been less than half that projected for the plan period as a whole.
* The housing target has not been influenced by the need to limit or avoid building on green belt land. The government has said that assessed need does not, on its own, represent a case for building on green belt land, but that is exactly what the plan argues.
* The mechanism that has been used for identifying sites is flawed. The Council simply asked land owners or developers to suggest sites that they would like to develop (at least one major site has been put forward by a developer who does not own the site concerned). There has been no attempt to identify sites that would be suitable for meeting housing need whilst meeting community and sustainability requirements. The result is that housing is proposed in the locations that suit the developers rather than those that provide the best solution for the community.
* The plan includes inadequate provisions to would ensure that brown field sites will be developed first with green field and green belt sites only following later if the demand is shown to exist.
* The traffic impact assessment is totally inadequate. The plan relies on an assessment that covers Stevenage, Hitchin and most of Letchworth and Baldock, together with another that covers Royston. The largest development proposed at Baldock is beyond the edge of the area covered by the traffic model. In addition whilst the effects of Stevenage and Welwyn Hatfield are considered, Central Bedfordshire and the proposed developments there are completely ignored. The supporting report sets an absurdly high threshold for congestion, only regarding junctions as congested if they will have "more than 100" vehicles queuing at the end of the peak hour. The proposed mitigation measures fail to identify the extent to which the problem will be improved and the proposals appear to take no account of traffic diversion to rural or residential roads.
The second level of objection is to the flaws in the proposals for individual sites:
1. GA2 - Tilekiln
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For most of its length if follows a footpath or a poorly defined field boundary. The strange shape of the site relates to land ownership rather than any natural feature and demonstrated that this is not a suitable boundary.
* Access to the site from Great Ashby is restricted to a narrow path through a wood land beneath powerlines.
* The site is proposed as the location for a school, but placing a school right on the edge of a settlement in this way will ensure that many children are brought by car.
* The development will clearly relate to Stevenage (despite being in North Herts) yet is remote from any of the town's facilities and will encourage longer car journeys to shops, secondary schools and leisure facilities.
2. GA1 - Roundwood
* Access to the site is unsatisfactory, requiring measures to prevent parking on roads in Great Ashby that are outside the site.
3. NS1 - North Stevenage
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For much of its length it is in the middle of a field.
* The site will clearly result in coalescence of Graveley with Stevenage. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* In addition it appears that access issues may not have been adequately considered.
4. WE1 - Weston
* Access to the Hitchin Road site needs to be from Hitchin Road and not from The Snipe.
*There is no pavement along a section of Hitchin Road that residents in the new development would need to use to get to the school, the shop and other village facilities. Any development here should require this to be addressed.
5. BA1 - Baldock
* The traffic assessments do not identify what would be required to make the large site north east of Baldock achievable.
* The land is admitted to "make a significant contribution to the Green Belt purposes".
* The site will clearly result in coalescence of Bygrave with Baldock. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* The National Planning Policy Framework requires that, for proposals of this sort, infrastructure should be planned at the same time as the Local Plan is prepared but there are no details of this in the plan.
* If built the proposed road linking the A505 with the A507 north of Baldock would have inevitably see use as a Baldock eastern by pass. Its specification and construction would need to reflect this use which would require placing significant parts of the road in a cutting to avoid unacceptable impacts on both the urban area and the adjacent countryside.

I wish to make the following representations in response to the Submission Draft Local Plan.

The whole plan is "unsound" because it is fundamentally flawed in a number of ways:
* The supposedly objective assessment of housing need is based simply on projections produced by the Office of National Statistics. No attempt has been made to validate these against past trends. In fact they would require that houses are built in North Herts at a greater rate than has ever happened in the past. Since the plan is for the period from 2011 to 2031 a quarter of the plan period has already happened. During that time the rate of development has been less than half that projected for the plan period as a whole.
* The housing target has not been influenced by the need to limit or avoid building on green belt land. The government has said that assessed need does not, on its own, represent a case for building on green belt land, but that is exactly what the plan argues.
* The mechanism that has been used for identifying sites is flawed. The Council simply asked land owners or developers to suggest sites that they would like to develop (at least one major site has been put forward by a developer who does not own the site concerned). There has been no attempt to identify sites that would be suitable for meeting housing need whilst meeting community and sustainability requirements. The result is that housing is proposed in the locations that suit the developers rather than those that provide the best solution for the community.
* The plan includes inadequate provisions to would ensure that brown field sites will be developed first with green field and green belt sites only following later if the demand is shown to exist.
* The traffic impact assessment is totally inadequate. The plan relies on an assessment that covers Stevenage, Hitchin and most of Letchworth and Baldock, together with another that covers Royston. The largest development proposed at Baldock is beyond the edge of the area covered by the traffic model. In addition whilst the effects of Stevenage and Welwyn Hatfield are considered, Central Bedfordshire and the proposed developments there are completely ignored. The supporting report sets an absurdly high threshold for congestion, only regarding junctions as congested if they will have "more than 100" vehicles queuing at the end of the peak hour. The proposed mitigation measures fail to identify the extent to which the problem will be improved and the proposals appear to take no account of traffic diversion to rural or residential roads.
The second level of objection is to the flaws in the proposals for individual sites:
1. GA2 - Tilekiln
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For most of its length if follows a footpath or a poorly defined field boundary. The strange shape of the site relates to land ownership rather than any natural feature and demonstrated that this is not a suitable boundary.
* Access to the site from Great Ashby is restricted to a narrow path through a wood land beneath powerlines.
* The site is proposed as the location for a school, but placing a school right on the edge of a settlement in this way will ensure that many children are brought by car.
* The development will clearly relate to Stevenage (despite being in North Herts) yet is remote from any of the town's facilities and will encourage longer car journeys to shops, secondary schools and leisure facilities.
2. GA1 - Roundwood
* Access to the site is unsatisfactory, requiring measures to prevent parking on roads in Great Ashby that are outside the site.
3. NS1 - North Stevenage
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For much of its length it is in the middle of a field.
* The site will clearly result in coalescence of Graveley with Stevenage. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* In addition it appears that access issues may not have been adequately considered.
4. WE1 - Weston
* Access to the Hitchin Road site needs to be from Hitchin Road and not from The Snipe.
*There is no pavement along a section of Hitchin Road that residents in the new development would need to use to get to the school, the shop and other village facilities. Any development here should require this to be addressed.
5. BA1 - Baldock
* The traffic assessments do not identify what would be required to make the large site north east of Baldock achievable.
* The land is admitted to "make a significant contribution to the Green Belt purposes".
* The site will clearly result in coalescence of Bygrave with Baldock. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* The National Planning Policy Framework requires that, for proposals of this sort, infrastructure should be planned at the same time as the Local Plan is prepared but there are no details of this in the plan.
* If built the proposed road linking the A505 with the A507 north of Baldock would have inevitably see use as a Baldock eastern by pass. Its specification and construction would need to reflect this use which would require placing significant parts of the road in a cutting to avoid unacceptable impacts on both the urban area and the adjacent countryside.

I wish to make the following representations in response to the Submission Draft Local Plan.

The whole plan is "unsound" because it is fundamentally flawed in a number of ways:
* The supposedly objective assessment of housing need is based simply on projections produced by the Office of National Statistics. No attempt has been made to validate these against past trends. In fact they would require that houses are built in North Herts at a greater rate than has ever happened in the past. Since the plan is for the period from 2011 to 2031 a quarter of the plan period has already happened. During that time the rate of development has been less than half that projected for the plan period as a whole.
* The housing target has not been influenced by the need to limit or avoid building on green belt land. The government has said that assessed need does not, on its own, represent a case for building on green belt land, but that is exactly what the plan argues.
* The mechanism that has been used for identifying sites is flawed. The Council simply asked land owners or developers to suggest sites that they would like to develop (at least one major site has been put forward by a developer who does not own the site concerned). There has been no attempt to identify sites that would be suitable for meeting housing need whilst meeting community and sustainability requirements. The result is that housing is proposed in the locations that suit the developers rather than those that provide the best solution for the community.
* The plan includes inadequate provisions to would ensure that brown field sites will be developed first with green field and green belt sites only following later if the demand is shown to exist.
* The traffic impact assessment is totally inadequate. The plan relies on an assessment that covers Stevenage, Hitchin and most of Letchworth and Baldock, together with another that covers Royston. The largest development proposed at Baldock is beyond the edge of the area covered by the traffic model. In addition whilst the effects of Stevenage and Welwyn Hatfield are considered, Central Bedfordshire and the proposed developments there are completely ignored. The supporting report sets an absurdly high threshold for congestion, only regarding junctions as congested if they will have "more than 100" vehicles queuing at the end of the peak hour. The proposed mitigation measures fail to identify the extent to which the problem will be improved and the proposals appear to take no account of traffic diversion to rural or residential roads.
The second level of objection is to the flaws in the proposals for individual sites:
1. GA2 - Tilekiln
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For most of its length if follows a footpath or a poorly defined field boundary. The strange shape of the site relates to land ownership rather than any natural feature and demonstrated that this is not a suitable boundary.
* Access to the site from Great Ashby is restricted to a narrow path through a wood land beneath powerlines.
* The site is proposed as the location for a school, but placing a school right on the edge of a settlement in this way will ensure that many children are brought by car.
* The development will clearly relate to Stevenage (despite being in North Herts) yet is remote from any of the town's facilities and will encourage longer car journeys to shops, secondary schools and leisure facilities.
2. GA1 - Roundwood
* Access to the site is unsatisfactory, requiring measures to prevent parking on roads in Great Ashby that are outside the site.
3. NS1 - North Stevenage
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For much of its length it is in the middle of a field.
* The site will clearly result in coalescence of Graveley with Stevenage. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* In addition it appears that access issues may not have been adequately considered.
4. WE1 - Weston
* Access to the Hitchin Road site needs to be from Hitchin Road and not from The Snipe.
*There is no pavement along a section of Hitchin Road that residents in the new development would need to use to get to the school, the shop and other village facilities. Any development here should require this to be addressed.
5. BA1 - Baldock
* The traffic assessments do not identify what would be required to make the large site north east of Baldock achievable.
* The land is admitted to "make a significant contribution to the Green Belt purposes".
* The site will clearly result in coalescence of Bygrave with Baldock. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* The National Planning Policy Framework requires that, for proposals of this sort, infrastructure should be planned at the same time as the Local Plan is prepared but there are no details of this in the plan.
* If built the proposed road linking the A505 with the A507 north of Baldock would have inevitably see use as a Baldock eastern by pass. Its specification and construction would need to reflect this use which would require placing significant parts of the road in a cutting to avoid unacceptable impacts on both the urban area and the adjacent countryside.

I wish to make the following representations in response to the Submission Draft Local Plan.

The whole plan is "unsound" because it is fundamentally flawed in a number of ways:
* The supposedly objective assessment of housing need is based simply on projections produced by the Office of National Statistics. No attempt has been made to validate these against past trends. In fact they would require that houses are built in North Herts at a greater rate than has ever happened in the past. Since the plan is for the period from 2011 to 2031 a quarter of the plan period has already happened. During that time the rate of development has been less than half that projected for the plan period as a whole.
* The housing target has not been influenced by the need to limit or avoid building on green belt land. The government has said that assessed need does not, on its own, represent a case for building on green belt land, but that is exactly what the plan argues.
* The mechanism that has been used for identifying sites is flawed. The Council simply asked land owners or developers to suggest sites that they would like to develop (at least one major site has been put forward by a developer who does not own the site concerned). There has been no attempt to identify sites that would be suitable for meeting housing need whilst meeting community and sustainability requirements. The result is that housing is proposed in the locations that suit the developers rather than those that provide the best solution for the community.
* The plan includes inadequate provisions to would ensure that brown field sites will be developed first with green field and green belt sites only following later if the demand is shown to exist.
* The traffic impact assessment is totally inadequate. The plan relies on an assessment that covers Stevenage, Hitchin and most of Letchworth and Baldock, together with another that covers Royston. The largest development proposed at Baldock is beyond the edge of the area covered by the traffic model. In addition whilst the effects of Stevenage and Welwyn Hatfield are considered, Central Bedfordshire and the proposed developments there are completely ignored. The supporting report sets an absurdly high threshold for congestion, only regarding junctions as congested if they will have "more than 100" vehicles queuing at the end of the peak hour. The proposed mitigation measures fail to identify the extent to which the problem will be improved and the proposals appear to take no account of traffic diversion to rural or residential roads.
The second level of objection is to the flaws in the proposals for individual sites:
1. GA2 - Tilekiln
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For most of its length if follows a footpath or a poorly defined field boundary. The strange shape of the site relates to land ownership rather than any natural feature and demonstrated that this is not a suitable boundary.
* Access to the site from Great Ashby is restricted to a narrow path through a wood land beneath powerlines.
* The site is proposed as the location for a school, but placing a school right on the edge of a settlement in this way will ensure that many children are brought by car.
* The development will clearly relate to Stevenage (despite being in North Herts) yet is remote from any of the town's facilities and will encourage longer car journeys to shops, secondary schools and leisure facilities.
2. GA1 - Roundwood
* Access to the site is unsatisfactory, requiring measures to prevent parking on roads in Great Ashby that are outside the site.
3. NS1 - North Stevenage
* The Green Belt boundary proposed around this development is unsuitable in that it does not follow any clearly defined natural features. For much of its length it is in the middle of a field.
* The site will clearly result in coalescence of Graveley with Stevenage. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* In addition it appears that access issues may not have been adequately considered.
4. WE1 - Weston
* Access to the Hitchin Road site needs to be from Hitchin Road and not from The Snipe.
*There is no pavement along a section of Hitchin Road that residents in the new development would need to use to get to the school, the shop and other village facilities. Any development here should require this to be addressed.
5. BA1 - Baldock
* The traffic assessments do not identify what would be required to make the large site north east of Baldock achievable.
* The land is admitted to "make a significant contribution to the Green Belt purposes".
* The site will clearly result in coalescence of Bygrave with Baldock. The Council claims that Green Belts only exist to prevent coalescence of towns with other towns, not with villages but a recent appeal decision by the Secretary of State at Sawston in Cambridgeshire makes it clear that avoidance of coalescence of with a village is one of the objectives of the Green Belt.
* The National Planning Policy Framework requires that, for proposals of this sort, infrastructure should be planned at the same time as the Local Plan is prepared but there are no details of this in the plan.
* If built the proposed road linking the A505 with the A507 north of Baldock would have inevitably see use as a Baldock eastern by pass. Its specification and construction would need to reflect this use which would require placing significant parts of the road in a cutting to avoid unacceptable impacts on both the urban area and the adjacent countryside.