Local Plan 2011-2031 Proposed Submission Draft

In particular, I wish to object to the massive proposed development at the Blackhorse Farm site to the north of Baldock. My objections are based primarily on two of the "Tests of Soundness" that Local Plans are required to meet: "Effective - the plan should be deliverable over its period and based on effective joint working on cross boundary strategic priorities;" "Consistent with national policy - the plan should enable the delivery of sustainable development in accordance with the policies in the National Planning Policy Framework."

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. Proposed new road connecting A507 and A505 5. Inadequate local infrastructure to support existing needs
6. Green Belt development Sections 1 to 3 also demonstrate that the planners have failed to consider the transport and congestion issues raised by their plans. It has become clear during recent public meetings that they have no strategy for addressing these issues, and some of the issues raised by the proposed Blackhorse Farm development are so extreme that there is no realistic solution.
It is shown below that Baldock is already struggling with over-stretched amenities and major traffic congestion, and the Local Plan would increase Baldock's size by 80%. At the junction with the A507 and my own road the traffic is horrendous in early morning and evening, between 4.30 and 7.30, we have cross hatchings at the bottom to allow people to access Icknield Way East but this is on the whole ignored, we currently have 4 roads converging here and it already over used.
Sensitive infill development in appropriate areas of Baldock would be beneficial, but wholesale dumping of 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 that have simply been ignored.
1. Traffic congestion in Baldock town centre Traffic access into Baldock is restricted by two major barriers: the railway line and the A1(M). As a result, a very high proportion of traffic entering or leaving Baldock is forced to cross one particular road junction in the town centre. This junction pre-dates the A1 and the railway by hundreds of years and was never intended to carry anything like the current volume of traffic. The junction in question is the one 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:
2. Traffic entering Baldock from the north west on the A507
3. Traffic entering Baldock from the north on the A1
4. Traffic entering Baldock from the north from Bygrave, Ashwell, Steeple Morden, Guilden Morden and all the surrounding villages;
5. Traffic entering Baldock from the north east on the A505;
6. Traffic entering Baldock from the south east on the A507. All these major traffic flows entering Baldock - plus all the corresponding traffic flows heading in the opposite direction - have to pass through this single junction. As a result, 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
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. Objective 2(c) of the Sustainability Appraisal Framework includes the sub-objective: "avoid exacerbating local traffic congestion", but it appears that this requirement has simply been ignored.

Access to Baldock Station. The problem described in the previous section is made considerably worse by the unfortunate fact that Baldock Station is located between the congested traffic junction and the barrier formed by the railway embankment. As a result, traffic heading towards the station has three options: Approach from the north via Station Road. This traffic has to pass through the constriction formed by the railway bridge, and this area is always massively congested during the rush hour. Approach from the south via Station Road. This traffic has to cross the congested traffic junction that was discussed in the previous section. Approach from the west via Icknield Way or Football Close. Both of these are residential streets with extensive on-road parking, so they are effectively only one car wide. During the evening rush hour, the arrival of each train from London frequently creates dangerous situations at the bottom of the station approach road as cars from the station try to force their way into the traffic and face resistance from frustrated motorists who have spent a long time in the queue. Cars turning right have to undertake a particularly dangerous manoeuvre.

Despite the suggestions of the planners that a high proportion of "affordable" housing will be included in the development, there is very little evidence that employment in Baldock will grow sufficiently to accommodate this influx of new workers, or that the jobs will be sufficiently highly paid to allow people to pay for these homes. The location of the Blackhorse Farm development so close to Baldock Station inevitably means that many of the houses will be sold to people who commute to London or Cambridge. It was admitted at one of the planning meetings that the developers might try to buy their way out of affordable housing commitments so that they could focus on selling to affluent commuters. If this occurs, then existing congestion problems will be made far worse. When Cllr. Levett was asked about this at a meeting on 12th July 2016 at Knights Templar School, he said that they were looking at walking and cycling options. It was pointed out to him that the railway bridge on North Road is only marginally wider than two cars, so the only cycling option is to sit between stationary cars in a traffic jam. The walking options are not much better because the pavements under the bridge are extremely narrow. At this point, he declared that this was not a planning problem. Once again, a fundamental weakness in the Local Plan is simply being kicked into the long grass to prevent the public or the Planning Inspector from commenting on it. 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 eventually published, it will demonstrate that this Local Plan is not in accordance with the National Planning Policy Framework and is not deliverable.
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".

Clearly, the railway is a major component of the public transport provision in Baldock, so it is important to consider whether it has the spare capacity to carry the additional traffic that would be generated by new developments in and around Baldock.

Baldock only has a small station, and many rail travellers are already forced to stand all the way to 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 year4 . Unfortunately, the additional capacity required in the rail network to support this simply does not exist, and would be massively expensive to create. One of the key constraints is the cost of upgrading the Welwyn Viaduct and the Welwyn tunnels from two tracks to four. 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. In the case of Baldock Station, there is no realistic expectation of any new capacity becoming available. Indeed, exactly the opposite seems to be happening. 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 seats5 . 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"

Baldock Planning Meeting, Knights Templar School, 9th November 2016. http://www.dearcustomerrelations.com/save-baldock-trains/ 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. Proposed new road connecting A507 and A505 Although the NHDC planners have not produced a Traffic Assessment for the Blackhorse Farm development, they have proposed a road linking the A507 north of Baldock to the A505 east of Baldock. Paragraph 4.179 of their "Final draft of the Local Plan" states: "The site is also large enough to support new schools, local facilities and a new link road, including an additional road bridge over the railway so that not all traffic has to use the Station Road bridge and the Whitehorse Street/Royston Road crossroads." In other words, the road would allow some traffic to avoid the junction that is discussed in Section 1 above. However, it is not explained how this link road will address the needs of the Blackhorse Farm development. People living on the new development are hardly likely to drive across to the other side of the railway line so they can enter Baldock via the same gridlocked junction from the east instead of from the north. The traffic implications of the proposed development are so serious that a Traffic Assessment based on rigorous traffic modelling should be published for public scrutiny and comment before the Local Plan goes to the Planning Inspector. The link road will, however, be a major benefit to traffic flowing between places such as Ampthill in the east and Royston in the west. Both of these roads are dual carriageway as they approach Baldock, so the link road can be expected to be equally busy.
Whether the planners intend it or not, this will become a major trunk road running through the development. To minimise air pollution problems in the development, the capacity of this road and its associated railway crossing will have to be sufficient to allow the traffic to move freely. Furthermore, to minimise noise pollution, the road will have to be set in a cutting below the level of the surrounding development. Since the railway is raised on an embankment in this area, a bridge over the embankment would have a major noise and visual impact on the surrounding area. It should therefore be a condition of this development that the road passes under the railway line (in a tunnel) rather than over it (via a bridge).

For the residents of the new development and the existing residents of Lower Bygrave, the design of this road and the associated railway crossing is a critical issue. During the Council Meeting on 24th July 2016, Cllr Levett said that the new road would probably join North Road near the turning for Radwell. However, he also said that they were forced to plan this development on Herts County Council land because no other land had been made available. I do not know whether it would be possible to bring the road as far north as the Radwell turning without leaving Herts CC land. If it has to be brought out further south, it would cause even more congestion during the rush hour and would presumably require existing houses to be demolished. Another problem with this road is that it effectively accepts that the Blackhorse Farm development can never become an integral part of Baldock. As explained in Sections 1 and 2 above, the railway and the traffic junction form a bottleneck between the new development and the centre of Baldock, and the proposed new road will do absolutely nothing to fix this. As a result, Baldock will develop like an hourglass with two physically-close but largely separate town centres linked by a narrow constriction. There is a real risk that the new road will mean that the Blackhorse Farm development will develop a closer affinity with towns such as Stotfold - which would only be about 2 miles away and linked by a fast road. Although the development would lie within the boundary of Baldock, it would be a ghetto having little involvement with the life of the town. This flies in the face of Section 2 of the National Planning Policy Framework which requires new developments to promote the vitality of associated town centres, and talks about developing on "accessible sites that are well connected to the town centre".

Baldock is one of only five Hertfordshire towns classed as being of national importance for its historic character, and the town centre contains over 100 listed buildings. Nobody - not even the NHDC planners - claims that the Blackhorse Farm development will enhance Baldock town centre.

Inadequate local amenities to support existing needs The number of houses allocated to Baldock will increase the population by 80%. Rather than seeking to preserve the character and heritage of this historic market town by sensitive and carefully planned development, it has simply been used as a dumping ground for a large number of houses in order to meet an unrealistic quota. The scale of development around Baldock is so far out of alignment with the current size of the town that it will inevitably place massive additional pressures on local amenities that are already overstretched. At local planning meetings, NHDC planners have been bombarded with questions and complaints about inadequate local amenities. Schools, doctors' surgeries and other basic amenities are already at full capacity. Even water supplies are inadequate (Affinity Water describes our area as being under "serious water stress", and there have been a number of incidents where residents of Upper Bygrave have lost water supplies completely

All in all I really don't think the this has been thought about fully and the proposal is very unfair that such a large proportion be assigned to the Baldock area.