Local Plan 2011-2031 Proposed Submission Draft

NHDC Proposed Local Plan October 2016
This letter sets out a number of objections to the proposed Local Plan dated October 2016 by NHDC based on two of the "Tests of Soundness" set out in the National Planning Policy Framework ("NPPF"), namely a Local Plan should be:
"Effective - the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities; and
Consistent with national policy - the plan should enable the delivery of
sustainable development in accordance with the policies in the
Framework."
The proposed Local Plan falls short in a number of areas, in particular:
the viability and vitality of Baldock;
inadequate plan for transport infrastructure in the North Herts area generally;
inadequate plan for transport infrastructure as a result of the proposed developments in Baldock, in particular BA1, BA2 and BA3;
inadequate plan for the development of core infrastructure such as schools, doctor surgeries, leisure facilities; and
impact on Green Belt
There is clearly a need to increase the housing capacity to allow for the expanding population and the increasing employment opportunities in London and surrounding areas. All areas must contribute to the expansion, however the proposals in the Local Plan are not workable and lack a holistic approach to transport and core infrastructure and will destroy the essence of the historic market town of Baldock.
The letter sets out in more detail the details of the objections and then discusses alternate ways and amendments that could achieve the objectives.
Viability and vitality of Baldock
Baldock is an historic market town with a vibrant community spirit. The centre of the town is characterised by a wide high street, numerous public houses and restaurants, specialised retail outlets including an award winning butchers. There are a number of events throughout the year that bring together the local community, in particular the Baldock festival in May, a free music festival in September, the charter fair in October, numerous farmers markets and other cultural events in the recently refurbished Town Hall and market square.
All of these events allow the people of Baldock to come together as a community and build friendships. The housing in Baldock itself is generally quite modest and therefore the people are of broadly like minds. Over the last 30 years there has been an expansion of housing, primarily on Clothall Common, but in smaller developments of up to 20 houses. This type of expansion enhances the community spirit in Baldock, however the town amenities are at capacity and the proposed increase of 80% more homes threatens to destroy the community spirit and overburden the amenities in the town centre which has limited capacity to expand.
The recreation facilities in the town are limited today. The Town Hall is recently refurbished and is operated by volunteers primarily for art and musical activities. The Community Centre has three function rooms which are used a variety of clubs for all ages. Both have limited capacity and are just about sufficient for the needs of the town, the proposed expansion would render them inadequate. There is a bowls and cricket club located on Avenue Park, which are popular, and Baldock Crusaders netball team use the public courts also at Avenue Park. These facilities are functional but have limited capacity. There is a junior football club (Baldock Town Youth FC) which uses pitches at Hartsfield School and Knights Templar School, the proposed increase in population would mean that more football pitches would need to be made available, preferably with a club house. There is no mention of provision of any additional recreational facilities in the proposed Local Plan.
Baldock has excellent schools, three primary and a secondary school (Knights Templar School). All work together well and receive good or outstanding reports from Ofsted and they are very much part of the community. All of the schools are at full capacity with limited (at best) room for expansion in buildings and facilities, and even less capacity financially, as recently highlighted by an appeal from Knights Templar to parents to help buy
equipment for a newly built science block. The proposed Local Plan sets out a policy for expanding capacity by 8FE, however there are no details on the location or timing of the building of this extra capacity. A condition of any permission must be the building of sufficient school capacity in advance of any housing expansion and that the new schools must be associated with the existing school structures.
The proposed Local Plan has failed to take into account adequately the unique community spirit, recreation facilities and schooling requirements and therefore fails the Test of Soundness to be consistent with national policy, in particular:
NPPF paragraph 70 requires a Local Plan to plan positively to deliver the social, recreational and cultural facilities and services the community needs - the lack of any provision in the proposed Local Plan for Baldock in BA1, BA2 and BA3 demonstrates this has not been done
NPPF paragraph 72 requires sufficient school places are available, the proposed Local Plan for Baldock in BA1, BA2 and BA3 lacks any detail on how and when this will be delivered.
NPPF paragraph 74 requires a Local Plan to provide access to high quality open spaces and opportunities for sport and recreation, in the proposed Local Plan for Baldock there is no acknowledgement of the limited capacity of current amenities or the need to create expanded facilities.
Transport in North Herts
The area between Hitchin, Letchworth and Baldock is already over capacity for the infrastructure that serves it. The employment level in the area is high but with limited jobs available in the immediate area, a significant amount of the people commute to work either by train or by car using transport links that are already at capacity, specifically:
peak time trains into and out of London are always crowded with inadequate seating and regular delays;
the train operating company has recently announced plans to change the service into London, it was reported at recent meeting that the councillor who prepared the plan was unaware of the changes and the adverse impact they would cause, in particular on off peak journey times and overall capacity;
the A1(M) has solid queues every day between 6.30 am and 9.15am from Junction 10 (Baldock Services) to Junction 6 (Welwyn Garden City) caused by only having 2 lanes for the majority of the distance and increase in usage over the last 10 years with the expansion in towns such as Biggleswade, Stotfold, Stevenage and Shefford;
in the evening peak between 4.30pm and 7.00pm there is a solid queue between Junction 5 and Junction 8
the main through road from Baldock to Hitchin (the B656) has queues into and out of Hitchin and Baldock because of the sheer weight of traffic
there is a significant pinch point at Junction 9 coming out of Letchworth, which causes drivers wishing to travel to Royston, Baldock and Buntingford to avoid this and go through Baldock town centre
As a result journey times are at least double what they should be with significant overcrowding on trains. The proposed expansion in housing proposed in the Local Plan will obviously increase significantly the demand on these key transport links, however it does not make any mention of proposals to alleviate the problem, therefore it is not consistent with national policy in a number of areas:
NPPF Paragraph 34 sets out "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised". With limited employment opportunities in the North Herts area the proposed developments have not considered minimising the need to travel.
NPPF Paragraph 36 requires that where there is a significant amount of movement a Travel Plan is published with the Local Plan. The expansion of Baldock by 80% qualifies as "significant amount of movement" and no Travel Plan has been produced.
Transport in Baldock
Baldock is an historic market town of approximately 4500 houses. The proposed Local Plan is seeking to increase the size of the town by 80%. The transport infrastructure does not cope with current demands and therefore an increase of 80% without significant infrastructure development will grind the town to a stop and the consequential impact on the town centre and
environment will increase public health issues and reduce the enjoyment of living in Baldock with its vibrant community spirit.
 The road system in Baldock has been shaped over hundreds of years and has a pinch point at an intersection of the A507 and B656, which is managed by traffic lights and the junction itself is surrounded by listed buildings which prevent any material changes to the junction.
 Traffic at peak times in the morning and evening mean queues onto the junction are regularly in excess of 10 minutes from all directions with the exception of cars coming from Royston.
The railway station is located near to the intersection, it has limited parking, and is accessed from the A507 approached from the North. As has been stated, there are always queues into the intersection and so getting access to the station by car takes significantly more time than necessary.
Approaching from the north of the town along the A507 there is a railway bridge which has very little space for pedestrians and cyclists to access alongside the queuing traffic. This particularly is dangerous, and with the proposed building of 2800 houses in site BA1 the situation will become critical and lives will be endangered. The proposed Local Plan does not have any policy to alleviate this issue.
The capacity of Baldock station is limited, there is not adequate covered area on the platform, parking spaces are limited but adequate, the ticket office is open for a limited time in the morning, there are no retail facilities or toilets, and the train operating company is proposing to change the off peak service times. It is a small station. It is fair to assume a large majority of the people who would move into the new houses will commute to London and therefore the station facilities must be upgraded as part of any proposed expansion in the town.
 Following the recent town centre development, parking in Baldock is limited but adequate for the demand today, and any material expansion in population will cause parking problems and there are no proposals to alleviate this.
The proposed southern link road associated with BA2 and BA3 has no details. Whilst it may alleviate some pressure on the intersection of the A507 and B656, it could create a route through the Clothall Common estate which will increase the safety of the residents who benefit from the estate being a no through road. Any proposed development should
simply create a junction between the A507 and the new A505 Baldock bypass.
In the proposed BA1 development, there is a proposal to create a link road from the A507 between Junction 10 of the A1(M) and the roundabout east of Baldock on the A505. This road will be extremely busy, it must be a dual carriageway and it must be built in a cutting with adequate provisions for noise and air pollution reduction. The proposed Local Plan does not provide any details of the nature of this road
Any one of these points on their own are enough to demonstrate the proposed Local Plan does not take into account the transport needs created by an expansion, but in aggregate they demonstrate the proposed Local Plan is unworkable and therefore fails the Test of Soundness on the grounds of not being Effective and inconsistent with national policy, in particular:
 NPPF paragraph 31 requires neighbouring authorities to be included in the development of strategic solutions for viable infrastructure, this clearly has not happened with the train company, Network Rail or the authority responsible for highways.
NPPF paragraph 35 requires the Local Plan should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. The lack of any proposals in BA1, BA2 or BA3 for improving pedestrian and cycling links, in particular through the railway bridge on the A507 demonstrates no consideration has been taken to encourage sustainable transport for Baldock.
NPPF paragraph 39 and 40 set out policies to ensure there is adequate parking in town centres. There are no proposals in BA1, BA2 or BA3 to address the increase in demand for the parking in Baldock town centre.
Core infrastructure in Baldock
Baldock has one doctors surgery which provides an excellent service but it is notoriously difficult to get an appointment. Parking at the surgery has been removed and there is no physical capacity to expand the practice. The proposed Local Plan for Baldock makes no proposals on the addition of additional GP capacity.
The nearest hospital is Lister in Stevenage. There has been considerable investment in the capacity and services at the hospital but it is still operating at capacity and the proposed increase in housing will place additional burden an already creaking system. There is no discussion on increasing the capacity of the hospital.
Baldock has two care homes for the elderly. The ageing population and increasing demands for social care mean that the existing social care provision will be inadequate for an expanded population. The proposed Local Plan makes no reference to how social services will be expanded to cope with demand of the residents as well as the increasing demands of the existing population.
I have already set out the position that the proposals in the Local Plan contain inadequate details about the provision of additional schooling, but this is another example of the lack of coordinated planning in the proposal.
Taken in aggregate the lack of provision in the proposed Local Plan for the Baldock area fails the Test of Soundness to be Effective and to be consistent with national policy, in particular:
The proposed Local Plan does not consider the broader infrastructure required to service the expanded the Baldock community;
NPPF paragraph 17 set out 12 Core Planning Principles that should underpin plan-making and decision-making, the proposed Local Plan does not apply the following:
o #3 - proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs;
o #4 - take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it;
o #11 - actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable; and
o #12 - take account of and support local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs.
Impact on Green Belt
Four of the large "strategic developments" proposed by NHDC, including the Blackhorse Farm development, have been located on Green Belt land. Paragraph 80 of the National Planning Policy Framework lists five purposes for the Green Belt:
1. to check the unrestricted sprawl of large built-up areas;
2. to prevent neighbouring towns merging into one another;
3. to assist in safeguarding the countryside from encroachment;
4. to preserve the setting and special character of historic towns; and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
Table 5 in the North Hertfordshire Green Belt Review6 provides a "Green Belt Review Assessment Matrix". The Green Belt has been divided into sectors, and each sector is subjectively assessed against the first four of the five Green Belt criteria listed above. However, the table does not provide any assessment in relation to the fifth criterion, which demonstrates there is no evidence of urban regeneration in this Local Plan.
The proposal in BA1 north of Baldock is clearly urban sprawl, and is exactly the kind of development the Green Belt was intended to prevent. How has this been allowed to happen when the scale of the site is so out of proportion with the size of Baldock? Through research it is clear that the site has been chosen out of political expediency as the land is owned by Hertfordshire County Council and by allocating such a large scale development without due consideration of the impact on the town of Baldock, as demonstrated in this letter, was the path of least resistance, ignoring the NPPF and best practice for planning.
NPPF paragraph 87 and 88 sets out that inappropriate development harmful to Green Belt will not be approved unless there are "very special circumstances". The proposed Local Plan does not make it clear what the very special
circumstances are that mean the significant development proposed in BA1 should be approved.
Alternative Approach
Having demonstrated the proposed Local Plan does not pass Tests of Soundness across a number of elements and therefore does not constitute a sustainable development, there is still the underlying need to increase the housing capacity. I believe a more strategic and holistic approach is needed, not just in North Herts but with associated districts, and such an approach needs to address the following points before any significant housing developments are started:
Increase the capacity of the A1(M) from Biggleswade to Welwyn to have at least 3 lane, but preferably 4 lane carriageways;
Build a bypass for the whole of the Hitchin, Letchworth and Baldock to alleviate the pressure on the B656 (old A505 route) and the associated pinch points such as the intersection between the A507 and the B6565 in Baldock. Wherever possible this bypass will be built in a cutting and be dual carriageway;
Identify a site where a new town, built on Garden City principles, for up to 10,000 houses and associated infrastructure can be built with close transport links to rail and road - the site West of Stevenage is ideal and a tram route can be built to transport commuters to Stevenage station;
Identify the site for a new hospital or significantly expand the capacity at Lister Hospital;
The plans for building on site BA1 should be shelved in favour of the consolidated larger new town;
To accommodate a small increase in housing in BA2 and BA3 in Baldock, there should be a new intersection built on the intersection of the A507 and A505 new Baldock bypass and an expansion of capacity in local schools, community amenities and social care provisions
Summary
The proposed Local Plan does not support the principle of sustainable development and fails Tests of Soundness on a number of levels. There is no fully costed plan because all of the elements such as transport and schooling have no details to be able to fully cost them. The approach seems to be build the housing then worry about the infrastructure later, this is totally flawed and
will destroy the viability and vitality local Baldock community. Finally, the sheer scale of the proposed expansion is out of all proportion and would in and of itself ruin the beautiful town of Baldock.

NHDC Proposed Local Plan October 2016
This letter sets out a number of objections to the proposed Local Plan dated October 2016 by NHDC based on two of the "Tests of Soundness" set out in the National Planning Policy Framework ("NPPF"), namely a Local Plan should be:
"Effective - the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities; and
Consistent with national policy - the plan should enable the delivery of
sustainable development in accordance with the policies in the
Framework."
The proposed Local Plan falls short in a number of areas, in particular:
the viability and vitality of Baldock;
inadequate plan for transport infrastructure in the North Herts area generally;
inadequate plan for transport infrastructure as a result of the proposed developments in Baldock, in particular BA1, BA2 and BA3;
inadequate plan for the development of core infrastructure such as schools, doctor surgeries, leisure facilities; and
impact on Green Belt
There is clearly a need to increase the housing capacity to allow for the expanding population and the increasing employment opportunities in London and surrounding areas. All areas must contribute to the expansion, however the proposals in the Local Plan are not workable and lack a holistic approach to transport and core infrastructure and will destroy the essence of the historic market town of Baldock.
The letter sets out in more detail the details of the objections and then discusses alternate ways and amendments that could achieve the objectives.
Viability and vitality of Baldock
Baldock is an historic market town with a vibrant community spirit. The centre of the town is characterised by a wide high street, numerous public houses and restaurants, specialised retail outlets including an award winning butchers. There are a number of events throughout the year that bring together the local community, in particular the Baldock festival in May, a free music festival in September, the charter fair in October, numerous farmers markets and other cultural events in the recently refurbished Town Hall and market square.
All of these events allow the people of Baldock to come together as a community and build friendships. The housing in Baldock itself is generally quite modest and therefore the people are of broadly like minds. Over the last 30 years there has been an expansion of housing, primarily on Clothall Common, but in smaller developments of up to 20 houses. This type of expansion enhances the community spirit in Baldock, however the town amenities are at capacity and the proposed increase of 80% more homes threatens to destroy the community spirit and overburden the amenities in the town centre which has limited capacity to expand.
The recreation facilities in the town are limited today. The Town Hall is recently refurbished and is operated by volunteers primarily for art and musical activities. The Community Centre has three function rooms which are used a variety of clubs for all ages. Both have limited capacity and are just about sufficient for the needs of the town, the proposed expansion would render them inadequate. There is a bowls and cricket club located on Avenue Park, which are popular, and Baldock Crusaders netball team use the public courts also at Avenue Park. These facilities are functional but have limited capacity. There is a junior football club (Baldock Town Youth FC) which uses pitches at Hartsfield School and Knights Templar School, the proposed increase in population would mean that more football pitches would need to be made available, preferably with a club house. There is no mention of provision of any additional recreational facilities in the proposed Local Plan.
Baldock has excellent schools, three primary and a secondary school (Knights Templar School). All work together well and receive good or outstanding reports from Ofsted and they are very much part of the community. All of the schools are at full capacity with limited (at best) room for expansion in buildings and facilities, and even less capacity financially, as recently highlighted by an appeal from Knights Templar to parents to help buy
equipment for a newly built science block. The proposed Local Plan sets out a policy for expanding capacity by 8FE, however there are no details on the location or timing of the building of this extra capacity. A condition of any permission must be the building of sufficient school capacity in advance of any housing expansion and that the new schools must be associated with the existing school structures.
The proposed Local Plan has failed to take into account adequately the unique community spirit, recreation facilities and schooling requirements and therefore fails the Test of Soundness to be consistent with national policy, in particular:
NPPF paragraph 70 requires a Local Plan to plan positively to deliver the social, recreational and cultural facilities and services the community needs - the lack of any provision in the proposed Local Plan for Baldock in BA1, BA2 and BA3 demonstrates this has not been done
NPPF paragraph 72 requires sufficient school places are available, the proposed Local Plan for Baldock in BA1, BA2 and BA3 lacks any detail on how and when this will be delivered.
NPPF paragraph 74 requires a Local Plan to provide access to high quality open spaces and opportunities for sport and recreation, in the proposed Local Plan for Baldock there is no acknowledgement of the limited capacity of current amenities or the need to create expanded facilities.
Transport in North Herts
The area between Hitchin, Letchworth and Baldock is already over capacity for the infrastructure that serves it. The employment level in the area is high but with limited jobs available in the immediate area, a significant amount of the people commute to work either by train or by car using transport links that are already at capacity, specifically:
peak time trains into and out of London are always crowded with inadequate seating and regular delays;
the train operating company has recently announced plans to change the service into London, it was reported at recent meeting that the councillor who prepared the plan was unaware of the changes and the adverse impact they would cause, in particular on off peak journey times and overall capacity;
the A1(M) has solid queues every day between 6.30 am and 9.15am from Junction 10 (Baldock Services) to Junction 6 (Welwyn Garden City) caused by only having 2 lanes for the majority of the distance and increase in usage over the last 10 years with the expansion in towns such as Biggleswade, Stotfold, Stevenage and Shefford;
in the evening peak between 4.30pm and 7.00pm there is a solid queue between Junction 5 and Junction 8
the main through road from Baldock to Hitchin (the B656) has queues into and out of Hitchin and Baldock because of the sheer weight of traffic
there is a significant pinch point at Junction 9 coming out of Letchworth, which causes drivers wishing to travel to Royston, Baldock and Buntingford to avoid this and go through Baldock town centre
As a result journey times are at least double what they should be with significant overcrowding on trains. The proposed expansion in housing proposed in the Local Plan will obviously increase significantly the demand on these key transport links, however it does not make any mention of proposals to alleviate the problem, therefore it is not consistent with national policy in a number of areas:
NPPF Paragraph 34 sets out "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised". With limited employment opportunities in the North Herts area the proposed developments have not considered minimising the need to travel.
NPPF Paragraph 36 requires that where there is a significant amount of movement a Travel Plan is published with the Local Plan. The expansion of Baldock by 80% qualifies as "significant amount of movement" and no Travel Plan has been produced.
Transport in Baldock
Baldock is an historic market town of approximately 4500 houses. The proposed Local Plan is seeking to increase the size of the town by 80%. The transport infrastructure does not cope with current demands and therefore an increase of 80% without significant infrastructure development will grind the town to a stop and the consequential impact on the town centre and
environment will increase public health issues and reduce the enjoyment of living in Baldock with its vibrant community spirit.
 The road system in Baldock has been shaped over hundreds of years and has a pinch point at an intersection of the A507 and B656, which is managed by traffic lights and the junction itself is surrounded by listed buildings which prevent any material changes to the junction.
 Traffic at peak times in the morning and evening mean queues onto the junction are regularly in excess of 10 minutes from all directions with the exception of cars coming from Royston.
The railway station is located near to the intersection, it has limited parking, and is accessed from the A507 approached from the North. As has been stated, there are always queues into the intersection and so getting access to the station by car takes significantly more time than necessary.
Approaching from the north of the town along the A507 there is a railway bridge which has very little space for pedestrians and cyclists to access alongside the queuing traffic. This particularly is dangerous, and with the proposed building of 2800 houses in site BA1 the situation will become critical and lives will be endangered. The proposed Local Plan does not have any policy to alleviate this issue.
The capacity of Baldock station is limited, there is not adequate covered area on the platform, parking spaces are limited but adequate, the ticket office is open for a limited time in the morning, there are no retail facilities or toilets, and the train operating company is proposing to change the off peak service times. It is a small station. It is fair to assume a large majority of the people who would move into the new houses will commute to London and therefore the station facilities must be upgraded as part of any proposed expansion in the town.
 Following the recent town centre development, parking in Baldock is limited but adequate for the demand today, and any material expansion in population will cause parking problems and there are no proposals to alleviate this.
The proposed southern link road associated with BA2 and BA3 has no details. Whilst it may alleviate some pressure on the intersection of the A507 and B656, it could create a route through the Clothall Common estate which will increase the safety of the residents who benefit from the estate being a no through road. Any proposed development should
simply create a junction between the A507 and the new A505 Baldock bypass.
In the proposed BA1 development, there is a proposal to create a link road from the A507 between Junction 10 of the A1(M) and the roundabout east of Baldock on the A505. This road will be extremely busy, it must be a dual carriageway and it must be built in a cutting with adequate provisions for noise and air pollution reduction. The proposed Local Plan does not provide any details of the nature of this road
Any one of these points on their own are enough to demonstrate the proposed Local Plan does not take into account the transport needs created by an expansion, but in aggregate they demonstrate the proposed Local Plan is unworkable and therefore fails the Test of Soundness on the grounds of not being Effective and inconsistent with national policy, in particular:
 NPPF paragraph 31 requires neighbouring authorities to be included in the development of strategic solutions for viable infrastructure, this clearly has not happened with the train company, Network Rail or the authority responsible for highways.
NPPF paragraph 35 requires the Local Plan should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. The lack of any proposals in BA1, BA2 or BA3 for improving pedestrian and cycling links, in particular through the railway bridge on the A507 demonstrates no consideration has been taken to encourage sustainable transport for Baldock.
NPPF paragraph 39 and 40 set out policies to ensure there is adequate parking in town centres. There are no proposals in BA1, BA2 or BA3 to address the increase in demand for the parking in Baldock town centre.
Core infrastructure in Baldock
Baldock has one doctors surgery which provides an excellent service but it is notoriously difficult to get an appointment. Parking at the surgery has been removed and there is no physical capacity to expand the practice. The proposed Local Plan for Baldock makes no proposals on the addition of additional GP capacity.
The nearest hospital is Lister in Stevenage. There has been considerable investment in the capacity and services at the hospital but it is still operating at capacity and the proposed increase in housing will place additional burden an already creaking system. There is no discussion on increasing the capacity of the hospital.
Baldock has two care homes for the elderly. The ageing population and increasing demands for social care mean that the existing social care provision will be inadequate for an expanded population. The proposed Local Plan makes no reference to how social services will be expanded to cope with demand of the residents as well as the increasing demands of the existing population.
I have already set out the position that the proposals in the Local Plan contain inadequate details about the provision of additional schooling, but this is another example of the lack of coordinated planning in the proposal.
Taken in aggregate the lack of provision in the proposed Local Plan for the Baldock area fails the Test of Soundness to be Effective and to be consistent with national policy, in particular:
The proposed Local Plan does not consider the broader infrastructure required to service the expanded the Baldock community;
NPPF paragraph 17 set out 12 Core Planning Principles that should underpin plan-making and decision-making, the proposed Local Plan does not apply the following:
o #3 - proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs;
o #4 - take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it;
o #11 - actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable; and
o #12 - take account of and support local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs.
Impact on Green Belt
Four of the large "strategic developments" proposed by NHDC, including the Blackhorse Farm development, have been located on Green Belt land. Paragraph 80 of the National Planning Policy Framework lists five purposes for the Green Belt:
1. to check the unrestricted sprawl of large built-up areas;
2. to prevent neighbouring towns merging into one another;
3. to assist in safeguarding the countryside from encroachment;
4. to preserve the setting and special character of historic towns; and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
Table 5 in the North Hertfordshire Green Belt Review6 provides a "Green Belt Review Assessment Matrix". The Green Belt has been divided into sectors, and each sector is subjectively assessed against the first four of the five Green Belt criteria listed above. However, the table does not provide any assessment in relation to the fifth criterion, which demonstrates there is no evidence of urban regeneration in this Local Plan.
The proposal in BA1 north of Baldock is clearly urban sprawl, and is exactly the kind of development the Green Belt was intended to prevent. How has this been allowed to happen when the scale of the site is so out of proportion with the size of Baldock? Through research it is clear that the site has been chosen out of political expediency as the land is owned by Hertfordshire County Council and by allocating such a large scale development without due consideration of the impact on the town of Baldock, as demonstrated in this letter, was the path of least resistance, ignoring the NPPF and best practice for planning.
NPPF paragraph 87 and 88 sets out that inappropriate development harmful to Green Belt will not be approved unless there are "very special circumstances". The proposed Local Plan does not make it clear what the very special
circumstances are that mean the significant development proposed in BA1 should be approved.
Alternative Approach
Having demonstrated the proposed Local Plan does not pass Tests of Soundness across a number of elements and therefore does not constitute a sustainable development, there is still the underlying need to increase the housing capacity. I believe a more strategic and holistic approach is needed, not just in North Herts but with associated districts, and such an approach needs to address the following points before any significant housing developments are started:
Increase the capacity of the A1(M) from Biggleswade to Welwyn to have at least 3 lane, but preferably 4 lane carriageways;
Build a bypass for the whole of the Hitchin, Letchworth and Baldock to alleviate the pressure on the B656 (old A505 route) and the associated pinch points such as the intersection between the A507 and the B6565 in Baldock. Wherever possible this bypass will be built in a cutting and be dual carriageway;
Identify a site where a new town, built on Garden City principles, for up to 10,000 houses and associated infrastructure can be built with close transport links to rail and road - the site West of Stevenage is ideal and a tram route can be built to transport commuters to Stevenage station;
Identify the site for a new hospital or significantly expand the capacity at Lister Hospital;
The plans for building on site BA1 should be shelved in favour of the consolidated larger new town;
To accommodate a small increase in housing in BA2 and BA3 in Baldock, there should be a new intersection built on the intersection of the A507 and A505 new Baldock bypass and an expansion of capacity in local schools, community amenities and social care provisions
Summary
The proposed Local Plan does not support the principle of sustainable development and fails Tests of Soundness on a number of levels. There is no fully costed plan because all of the elements such as transport and schooling have no details to be able to fully cost them. The approach seems to be build the housing then worry about the infrastructure later, this is totally flawed and
will destroy the viability and vitality local Baldock community. Finally, the sheer scale of the proposed expansion is out of all proportion and would in and of itself ruin the beautiful town of Baldock.

NHDC Proposed Local Plan October 2016
This letter sets out a number of objections to the proposed Local Plan dated October 2016 by NHDC based on two of the "Tests of Soundness" set out in the National Planning Policy Framework ("NPPF"), namely a Local Plan should be:
"Effective - the plan should be deliverable over its period and based on
effective joint working on cross-boundary strategic priorities; and
Consistent with national policy - the plan should enable the delivery of
sustainable development in accordance with the policies in the
Framework."
The proposed Local Plan falls short in a number of areas, in particular:
the viability and vitality of Baldock;
inadequate plan for transport infrastructure in the North Herts area generally;
inadequate plan for transport infrastructure as a result of the proposed developments in Baldock, in particular BA1, BA2 and BA3;
inadequate plan for the development of core infrastructure such as schools, doctor surgeries, leisure facilities; and
impact on Green Belt
There is clearly a need to increase the housing capacity to allow for the expanding population and the increasing employment opportunities in London and surrounding areas. All areas must contribute to the expansion, however the proposals in the Local Plan are not workable and lack a holistic approach to transport and core infrastructure and will destroy the essence of the historic market town of Baldock.
The letter sets out in more detail the details of the objections and then discusses alternate ways and amendments that could achieve the objectives.
Viability and vitality of Baldock
Baldock is an historic market town with a vibrant community spirit. The centre of the town is characterised by a wide high street, numerous public houses and restaurants, specialised retail outlets including an award winning butchers. There are a number of events throughout the year that bring together the local community, in particular the Baldock festival in May, a free music festival in September, the charter fair in October, numerous farmers markets and other cultural events in the recently refurbished Town Hall and market square.
All of these events allow the people of Baldock to come together as a community and build friendships. The housing in Baldock itself is generally quite modest and therefore the people are of broadly like minds. Over the last 30 years there has been an expansion of housing, primarily on Clothall Common, but in smaller developments of up to 20 houses. This type of expansion enhances the community spirit in Baldock, however the town amenities are at capacity and the proposed increase of 80% more homes threatens to destroy the community spirit and overburden the amenities in the town centre which has limited capacity to expand.
The recreation facilities in the town are limited today. The Town Hall is recently refurbished and is operated by volunteers primarily for art and musical activities. The Community Centre has three function rooms which are used a variety of clubs for all ages. Both have limited capacity and are just about sufficient for the needs of the town, the proposed expansion would render them inadequate. There is a bowls and cricket club located on Avenue Park, which are popular, and Baldock Crusaders netball team use the public courts also at Avenue Park. These facilities are functional but have limited capacity. There is a junior football club (Baldock Town Youth FC) which uses pitches at Hartsfield School and Knights Templar School, the proposed increase in population would mean that more football pitches would need to be made available, preferably with a club house. There is no mention of provision of any additional recreational facilities in the proposed Local Plan.
Baldock has excellent schools, three primary and a secondary school (Knights Templar School). All work together well and receive good or outstanding reports from Ofsted and they are very much part of the community. All of the schools are at full capacity with limited (at best) room for expansion in buildings and facilities, and even less capacity financially, as recently highlighted by an appeal from Knights Templar to parents to help buy
equipment for a newly built science block. The proposed Local Plan sets out a policy for expanding capacity by 8FE, however there are no details on the location or timing of the building of this extra capacity. A condition of any permission must be the building of sufficient school capacity in advance of any housing expansion and that the new schools must be associated with the existing school structures.
The proposed Local Plan has failed to take into account adequately the unique community spirit, recreation facilities and schooling requirements and therefore fails the Test of Soundness to be consistent with national policy, in particular:
NPPF paragraph 70 requires a Local Plan to plan positively to deliver the social, recreational and cultural facilities and services the community needs - the lack of any provision in the proposed Local Plan for Baldock in BA1, BA2 and BA3 demonstrates this has not been done
NPPF paragraph 72 requires sufficient school places are available, the proposed Local Plan for Baldock in BA1, BA2 and BA3 lacks any detail on how and when this will be delivered.
NPPF paragraph 74 requires a Local Plan to provide access to high quality open spaces and opportunities for sport and recreation, in the proposed Local Plan for Baldock there is no acknowledgement of the limited capacity of current amenities or the need to create expanded facilities.
Transport in North Herts
The area between Hitchin, Letchworth and Baldock is already over capacity for the infrastructure that serves it. The employment level in the area is high but with limited jobs available in the immediate area, a significant amount of the people commute to work either by train or by car using transport links that are already at capacity, specifically:
peak time trains into and out of London are always crowded with inadequate seating and regular delays;
the train operating company has recently announced plans to change the service into London, it was reported at recent meeting that the councillor who prepared the plan was unaware of the changes and the adverse impact they would cause, in particular on off peak journey times and overall capacity;
the A1(M) has solid queues every day between 6.30 am and 9.15am from Junction 10 (Baldock Services) to Junction 6 (Welwyn Garden City) caused by only having 2 lanes for the majority of the distance and increase in usage over the last 10 years with the expansion in towns such as Biggleswade, Stotfold, Stevenage and Shefford;
in the evening peak between 4.30pm and 7.00pm there is a solid queue between Junction 5 and Junction 8
the main through road from Baldock to Hitchin (the B656) has queues into and out of Hitchin and Baldock because of the sheer weight of traffic
there is a significant pinch point at Junction 9 coming out of Letchworth, which causes drivers wishing to travel to Royston, Baldock and Buntingford to avoid this and go through Baldock town centre
As a result journey times are at least double what they should be with significant overcrowding on trains. The proposed expansion in housing proposed in the Local Plan will obviously increase significantly the demand on these key transport links, however it does not make any mention of proposals to alleviate the problem, therefore it is not consistent with national policy in a number of areas:
NPPF Paragraph 34 sets out "Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised". With limited employment opportunities in the North Herts area the proposed developments have not considered minimising the need to travel.
NPPF Paragraph 36 requires that where there is a significant amount of movement a Travel Plan is published with the Local Plan. The expansion of Baldock by 80% qualifies as "significant amount of movement" and no Travel Plan has been produced.
Transport in Baldock
Baldock is an historic market town of approximately 4500 houses. The proposed Local Plan is seeking to increase the size of the town by 80%. The transport infrastructure does not cope with current demands and therefore an increase of 80% without significant infrastructure development will grind the town to a stop and the consequential impact on the town centre and
environment will increase public health issues and reduce the enjoyment of living in Baldock with its vibrant community spirit.
 The road system in Baldock has been shaped over hundreds of years and has a pinch point at an intersection of the A507 and B656, which is managed by traffic lights and the junction itself is surrounded by listed buildings which prevent any material changes to the junction.
 Traffic at peak times in the morning and evening mean queues onto the junction are regularly in excess of 10 minutes from all directions with the exception of cars coming from Royston.
The railway station is located near to the intersection, it has limited parking, and is accessed from the A507 approached from the North. As has been stated, there are always queues into the intersection and so getting access to the station by car takes significantly more time than necessary.
Approaching from the north of the town along the A507 there is a railway bridge which has very little space for pedestrians and cyclists to access alongside the queuing traffic. This particularly is dangerous, and with the proposed building of 2800 houses in site BA1 the situation will become critical and lives will be endangered. The proposed Local Plan does not have any policy to alleviate this issue.
The capacity of Baldock station is limited, there is not adequate covered area on the platform, parking spaces are limited but adequate, the ticket office is open for a limited time in the morning, there are no retail facilities or toilets, and the train operating company is proposing to change the off peak service times. It is a small station. It is fair to assume a large majority of the people who would move into the new houses will commute to London and therefore the station facilities must be upgraded as part of any proposed expansion in the town.
 Following the recent town centre development, parking in Baldock is limited but adequate for the demand today, and any material expansion in population will cause parking problems and there are no proposals to alleviate this.
The proposed southern link road associated with BA2 and BA3 has no details. Whilst it may alleviate some pressure on the intersection of the A507 and B656, it could create a route through the Clothall Common estate which will increase the safety of the residents who benefit from the estate being a no through road. Any proposed development should
simply create a junction between the A507 and the new A505 Baldock bypass.
In the proposed BA1 development, there is a proposal to create a link road from the A507 between Junction 10 of the A1(M) and the roundabout east of Baldock on the A505. This road will be extremely busy, it must be a dual carriageway and it must be built in a cutting with adequate provisions for noise and air pollution reduction. The proposed Local Plan does not provide any details of the nature of this road
Any one of these points on their own are enough to demonstrate the proposed Local Plan does not take into account the transport needs created by an expansion, but in aggregate they demonstrate the proposed Local Plan is unworkable and therefore fails the Test of Soundness on the grounds of not being Effective and inconsistent with national policy, in particular:
 NPPF paragraph 31 requires neighbouring authorities to be included in the development of strategic solutions for viable infrastructure, this clearly has not happened with the train company, Network Rail or the authority responsible for highways.
NPPF paragraph 35 requires the Local Plan should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. The lack of any proposals in BA1, BA2 or BA3 for improving pedestrian and cycling links, in particular through the railway bridge on the A507 demonstrates no consideration has been taken to encourage sustainable transport for Baldock.
NPPF paragraph 39 and 40 set out policies to ensure there is adequate parking in town centres. There are no proposals in BA1, BA2 or BA3 to address the increase in demand for the parking in Baldock town centre.
Core infrastructure in Baldock
Baldock has one doctors surgery which provides an excellent service but it is notoriously difficult to get an appointment. Parking at the surgery has been removed and there is no physical capacity to expand the practice. The proposed Local Plan for Baldock makes no proposals on the addition of additional GP capacity.
The nearest hospital is Lister in Stevenage. There has been considerable investment in the capacity and services at the hospital but it is still operating at capacity and the proposed increase in housing will place additional burden an already creaking system. There is no discussion on increasing the capacity of the hospital.
Baldock has two care homes for the elderly. The ageing population and increasing demands for social care mean that the existing social care provision will be inadequate for an expanded population. The proposed Local Plan makes no reference to how social services will be expanded to cope with demand of the residents as well as the increasing demands of the existing population.
I have already set out the position that the proposals in the Local Plan contain inadequate details about the provision of additional schooling, but this is another example of the lack of coordinated planning in the proposal.
Taken in aggregate the lack of provision in the proposed Local Plan for the Baldock area fails the Test of Soundness to be Effective and to be consistent with national policy, in particular:
The proposed Local Plan does not consider the broader infrastructure required to service the expanded the Baldock community;
NPPF paragraph 17 set out 12 Core Planning Principles that should underpin plan-making and decision-making, the proposed Local Plan does not apply the following:
o #3 - proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs;
o #4 - take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it;
o #11 - actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable; and
o #12 - take account of and support local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs.
Impact on Green Belt
Four of the large "strategic developments" proposed by NHDC, including the Blackhorse Farm development, have been located on Green Belt land. Paragraph 80 of the National Planning Policy Framework lists five purposes for the Green Belt:
1. to check the unrestricted sprawl of large built-up areas;
2. to prevent neighbouring towns merging into one another;
3. to assist in safeguarding the countryside from encroachment;
4. to preserve the setting and special character of historic towns; and
5. to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.
Table 5 in the North Hertfordshire Green Belt Review6 provides a "Green Belt Review Assessment Matrix". The Green Belt has been divided into sectors, and each sector is subjectively assessed against the first four of the five Green Belt criteria listed above. However, the table does not provide any assessment in relation to the fifth criterion, which demonstrates there is no evidence of urban regeneration in this Local Plan.
The proposal in BA1 north of Baldock is clearly urban sprawl, and is exactly the kind of development the Green Belt was intended to prevent. How has this been allowed to happen when the scale of the site is so out of proportion with the size of Baldock? Through research it is clear that the site has been chosen out of political expediency as the land is owned by Hertfordshire County Council and by allocating such a large scale development without due consideration of the impact on the town of Baldock, as demonstrated in this letter, was the path of least resistance, ignoring the NPPF and best practice for planning.
NPPF paragraph 87 and 88 sets out that inappropriate development harmful to Green Belt will not be approved unless there are "very special circumstances". The proposed Local Plan does not make it clear what the very special
circumstances are that mean the significant development proposed in BA1 should be approved.
Alternative Approach
Having demonstrated the proposed Local Plan does not pass Tests of Soundness across a number of elements and therefore does not constitute a sustainable development, there is still the underlying need to increase the housing capacity. I believe a more strategic and holistic approach is needed, not just in North Herts but with associated districts, and such an approach needs to address the following points before any significant housing developments are started:
Increase the capacity of the A1(M) from Biggleswade to Welwyn to have at least 3 lane, but preferably 4 lane carriageways;
Build a bypass for the whole of the Hitchin, Letchworth and Baldock to alleviate the pressure on the B656 (old A505 route) and the associated pinch points such as the intersection between the A507 and the B6565 in Baldock. Wherever possible this bypass will be built in a cutting and be dual carriageway;
Identify a site where a new town, built on Garden City principles, for up to 10,000 houses and associated infrastructure can be built with close transport links to rail and road - the site West of Stevenage is ideal and a tram route can be built to transport commuters to Stevenage station;
Identify the site for a new hospital or significantly expand the capacity at Lister Hospital;
The plans for building on site BA1 should be shelved in favour of the consolidated larger new town;
To accommodate a small increase in housing in BA2 and BA3 in Baldock, there should be a new intersection built on the intersection of the A507 and A505 new Baldock bypass and an expansion of capacity in local schools, community amenities and social care provisions
Summary
The proposed Local Plan does not support the principle of sustainable development and fails Tests of Soundness on a number of levels. There is no fully costed plan because all of the elements such as transport and schooling have no details to be able to fully cost them. The approach seems to be build the housing then worry about the infrastructure later, this is totally flawed and
will destroy the viability and vitality local Baldock community. Finally, the sheer scale of the proposed expansion is out of all proportion and would in and of itself ruin the beautiful town of Baldock.