Local Plan 2011-2031 Proposed Submission Draft

I am writing to comment on the North Hertfordshire District Council's Local Plan 2011 - 2031. In particular, I wish to object to the massive proposed development at the Blackhorse Farm site to the north of Baldock.
My comments below identify six areas in which the Local Plan clearly fails to meet the requirements of the National Planning Policy Framework:
1. Traffic congestion in Baldock town centre
2. Access to Baldock station
3. Capacity restrictions at Baldock Station
4. Green Belt development
5 Water
Sections 1 to 3 demonstrate that the planners have failed to consider the transport and congestion issues. There appears to be no strategy for addressing these issues. I therefore believe that the Baldock part of the Local Plan is simply not deliverable, and so fails two of the four Tests of Soundness.
Baldock is already struggling with major traffic congestion, and the Local Plan would considerably increase the size of the town. Sensitive infill development in appropriate areas of Baldock would be beneficial, but inflicting a major part of NHDC's housing requirement on one small town without any attempt to address the inadequate infrastructure will have very serious consequences.
1. Traffic congestion in Baldock town centre
Traffic access into Baldock is very congested at the junction where the A507 North Road meets the Royston Road (the old route of the A505) at the junction of Whitehorse Street, Station Road, Royston Road and Clothall Road. This junction is used by: traffic entering Baldock from the north west on the A507; traffic entering Baldock from the north on the A1; traffic entering Baldock from the north from all the surrounding villages; traffic entering Baldock from the north east on the A505; traffic entering Baldock from the south east on the A507.
All these major traffic flows entering Baldock have to pass through this single junction which cannot cope with the current volume of traffic. The junction is always congested, and congestion during the rush hour can extend back almost as far as the Baldock services.
Air pollution levels between the railway bridge and the junction are particularly high during the rush hour, and are probably higher than anywhere else in Baldock. It was stated during public meetings on the draft Local Plan that Baldock has an existing air quality problem, and that the "Baldock bowl" concentrates particulates from traffic exhausts.
Building 2,800 houses on the Blackhorse Farm site is about the worst possible thing that could happen in this part of Baldock. Planning should be about enabling the town to expand in a sustainable way, but adding approximately 5,600 cars to an area that is already massively congested will simply lead to gridlock and will further exacerbate the air pollution problem.

2. Access to Baldock Station
The entrance to Baldock Station is on the road leading to the above mentioned congested junction.
There is almost always heavy traffic entering Baldock by the station entrance and a steady flow of traffic from the traffic lights at the major junction. The station entrance is further complicated by Icknield Way, Football Close and Salisbury Road all joining at the same point. I live in Church Street and trying to drive out onto the A507 is very difficult. It is also extremely difficult for pedestrians to cross to go to the station with cars coming from 6 directions.
Inevitably many of the houses on the proposed Blackhorse Farm site will be sold to people who commute to London or Cambridge and the existing congestion problems will be made far worse.
The railway bridge on North Road is only marginally wider than two cars, so it is not possible to make a cycle path from the Blackhorse Farm site.
Paragraph 32 of the National Planning Policy Framework requires the Blackhorse Farm proposals to be supported by a Transport Assessment to show how these issues will be resolved, and Paragraph 177 of the same document requires infrastructure development policies to be included in the Local Plan. When the Transport Assessment is published, it will demonstrate that this Local Plan is not in accordance with the National Planning Policy Framework and is not deliverable.
3. Capacity restrictions at Baldock Station
The National Planning Policy Framework requires a Transport Assessment that emphasises "alternatives to the car such as walking, cycling and public transport". Baldock station is very busy, both during the week and at weekends. Many rail travellers are already forced to stand all the way to and from London. It has been estimated that the Local Plan will increase the number of rail journeys for Baldock from 330,000 to 600,000 per year.
The "Draft Sustainability Appraisal of North Hertfordshire Proposed Submission Local Plan" by CAG Consultants suggests that high density developments should be allowed in close proximity to town centres or railway stations. However, this pre-supposes that the railway station has the spare capacity needed to carry the additional passengers that will be generated by the development.
Under plans announced by Govia Thameslink in their 2018 timetable consultation, Baldock is set to lose semi-fast services to and from London in order to free-up capacity for services to other places further up the line with even more pressing needs. They will also be replacing the existing trains with newer models that provide air conditioning - but 30% fewer seats . Far from the integrated approach to housing and transport planning advocated by Paragraph 31 of the National Planning Policy Framework,
"Local authorities should work with neighbouring authorities and transport providers to develop strategies for the provision of viable infrastructure necessary to support sustainable development"
the local authority and the transport provider in Baldock are working against each other to make the situation far, far worse.
The Local Plan proposes to increase the population of Baldock by 80%. These new residents will need employment so that they can afford to buy the proposed new houses. Whether they travel to work by road or by rail, it is clear from the arguments above that they will create unsustainable levels of congestion that cannot be mitigated by any realistic investment in new infrastructure. This Local Plan is therefore not deliverable.
4. Green Belt development
The Blackhorse Farm development, is on Green Belt land and would result in urban sprawl that the Green Belt was meant to prevent. There is space to build between the Baldock Bypass and the railway line, north of Clothall Common, without building on perfectly good arable land and extending the boundaries of the town.
I feel very strongly that we should be doing everything in our power to protect the Green Belt - particularly since there are other sites available that DO meet planning criteria and are NOT in the Green Belt.
5. Water
I am concerned about water as a resource. We live in a very dry part of the country and rely on ground water from aquifers under the chalk. We are already extracting water at a faster rate than it is being replenished and 3500 more houses will be a huge increased and unsustainable demand.