Local Plan 2011-2031 Proposed Submission Draft

I am writing to object to the North Hertfordshire District Council's Local Plan 2011-2031, and in particular to proposed site BA1, the Blackhorse Farm site to the north of Baldock. as I believe it does not fully meet the soundness criteria laid out by the National Planning Policy Framework (NPPF).

1.Traffic congestion:
*The junction where the A507 and A505 cross already suffers from considerable congestion during peak periods, and it has been getting steadily worse in recent years. These cross roads are constricted by listed buildings, one of which has been damaged several times as a result of limited space to manoeuvre for some of the larger vehicles that use these routes. The 14'6" railway bridge on Station Road is frequently hit by lorries, despite recent work undertaken to reduce such incidents. These traffic issues are further exacerbated by any incidents occurring on the A1. Building 2800 houses (equating to c. 5600 cars) is only going to cause gridlock at an already excessively congested junction.
* Policy SP14 in the local plan suggests a new link road between the A505 and the A507 so that not all traffic from the proposed site will have to use the crossroads, however inevitably not all of the additional vehicles will elect to use the new route, therefore substantially increasing congestion at the crossroads.
*The NPPF (section 4) indicates that as part of promoting sustainable transport, a transport statement/assessment should be generated for any developments that generate significant amounts of movement. To my knowledge, there is no evidence that such an assessment has been generated which means the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

2.Green Belt:
*It is not acceptable to remove green belt status from land surrounding Baldock simply to meet housing requirements, even if land elsewhere is awarded green belt status to compensate. In my opinion this calls into question the whole concept of green belt policy.
*The proposal for the Blackhorse Farm site is a clear demonstration of urban sprawl, precisely the kind of development that green belt status is intended to prevent. This area is good quality agricultural land, and a haven for walkers, runners and cyclists.
*The NPPF (section 9) states that once established, Green Belt boundaries should only be altered in exceptional circumstances. NHDC have failed to demonstrate what these exceptional circumstances might be and therefore the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

3.Air quality and pollution:
*Baldock is located in a valley and as a result suffers from high levels of air pollution. The bypass to the east of Baldock helped to allieviate this initially, but traffic volumes (and therefore air pollution) have subsequently risen in recent years resulting in pollution levels in Hitchin St and Whitehorse St now being in danger of breaching levels permitted by EU law.
*The additional vehicles resulting from the proposed development on the Blackhorse Farm site will increase traffic in and around Baldock, thereby increasing pollution levels further and adversely impacting the health of local residents.
*The NPPF (section 1) indicates that to prevent unacceptable risks from pollution, there is a requirement to ensure that any new development is appropriate for its location, and the effects of pollution on health, and the potential sensitivity of the area to adverse effects from pollution should be taken into account. Given the already excessive levels of pollution currently plaguing Baldock I would suggest that this has not been taken into account and that therefore the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

4.Employment:
*A significant number of Baldock residents commute outside of the immediate area for work, to London, Cambridge, Stevenage, Welwyn/Hatfield and further afield, particularly higher skilled residents who are less able to find appropriate employment in the immediate vicinity.
*Policy SP3 describes additional employment provision for the area, and also indicates that the council will promote and support the expansion of the knowledge based economy in the area. However such action is unlikely to absorb the majority of the working population likely to inhabit the dwellings proposed for the Blackhorse Farm site. Realistically these people will be commuting in the same way as existing residents of Baldock, and placing increased pressure on already congested road and rail networks.
*The NPPF (paragraph 34) states indicates that plans and decisions should ensure developments that generate significant movements are located where the need to travel will be minimised. Since sufficient employment opportunities are unlikely to be made available in the immediate area, and therefore result in a significant increase in the number of people commuting outside the area, I would suggest that the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

To conclude, I feel that the proposal for the development of the Blackhorse Farm site is hugely inequitable when you consider the suggested number of houses in comparison to the existing number, and then further compare this to the number of houses that other towns in the local area have been asked to accommodate. It will dramatically compound already existing problems with regards to traffic congestion, pollution, and access to local amenities, and furthermore has the potential to destroy a charming town centre. I support careful, well thought out development that will enhance the local area, but what is being proposed is far removed from this and cannot be a good thing.

I am writing to object to the North Hertfordshire District Council's Local Plan 2011-2031, and in particular to proposed site BA1, the Blackhorse Farm site to the north of Baldock. as I believe it does not fully meet the soundness criteria laid out by the National Planning Policy Framework (NPPF).

1.Traffic congestion:
*The junction where the A507 and A505 cross already suffers from considerable congestion during peak periods, and it has been getting steadily worse in recent years. These cross roads are constricted by listed buildings, one of which has been damaged several times as a result of limited space to manoeuvre for some of the larger vehicles that use these routes. The 14'6" railway bridge on Station Road is frequently hit by lorries, despite recent work undertaken to reduce such incidents. These traffic issues are further exacerbated by any incidents occurring on the A1. Building 2800 houses (equating to c. 5600 cars) is only going to cause gridlock at an already excessively congested junction.
* Policy SP14 in the local plan suggests a new link road between the A505 and the A507 so that not all traffic from the proposed site will have to use the crossroads, however inevitably not all of the additional vehicles will elect to use the new route, therefore substantially increasing congestion at the crossroads.
*The NPPF (section 4) indicates that as part of promoting sustainable transport, a transport statement/assessment should be generated for any developments that generate significant amounts of movement. To my knowledge, there is no evidence that such an assessment has been generated which means the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

2.Green Belt:
*It is not acceptable to remove green belt status from land surrounding Baldock simply to meet housing requirements, even if land elsewhere is awarded green belt status to compensate. In my opinion this calls into question the whole concept of green belt policy.
*The proposal for the Blackhorse Farm site is a clear demonstration of urban sprawl, precisely the kind of development that green belt status is intended to prevent. This area is good quality agricultural land, and a haven for walkers, runners and cyclists.
*The NPPF (section 9) states that once established, Green Belt boundaries should only be altered in exceptional circumstances. NHDC have failed to demonstrate what these exceptional circumstances might be and therefore the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

3.Air quality and pollution:
*Baldock is located in a valley and as a result suffers from high levels of air pollution. The bypass to the east of Baldock helped to allieviate this initially, but traffic volumes (and therefore air pollution) have subsequently risen in recent years resulting in pollution levels in Hitchin St and Whitehorse St now being in danger of breaching levels permitted by EU law.
*The additional vehicles resulting from the proposed development on the Blackhorse Farm site will increase traffic in and around Baldock, thereby increasing pollution levels further and adversely impacting the health of local residents.
*The NPPF (section 1) indicates that to prevent unacceptable risks from pollution, there is a requirement to ensure that any new development is appropriate for its location, and the effects of pollution on health, and the potential sensitivity of the area to adverse effects from pollution should be taken into account. Given the already excessive levels of pollution currently plaguing Baldock I would suggest that this has not been taken into account and that therefore the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

4.Employment:
*A significant number of Baldock residents commute outside of the immediate area for work, to London, Cambridge, Stevenage, Welwyn/Hatfield and further afield, particularly higher skilled residents who are less able to find appropriate employment in the immediate vicinity.
*Policy SP3 describes additional employment provision for the area, and also indicates that the council will promote and support the expansion of the knowledge based economy in the area. However such action is unlikely to absorb the majority of the working population likely to inhabit the dwellings proposed for the Blackhorse Farm site. Realistically these people will be commuting in the same way as existing residents of Baldock, and placing increased pressure on already congested road and rail networks.
*The NPPF (paragraph 34) states indicates that plans and decisions should ensure developments that generate significant movements are located where the need to travel will be minimised. Since sufficient employment opportunities are unlikely to be made available in the immediate area, and therefore result in a significant increase in the number of people commuting outside the area, I would suggest that the plan fails to meet the NPPF soundness criteria of being consistent with national policy.

To conclude, I feel that the proposal for the development of the Blackhorse Farm site is hugely inequitable when you consider the suggested number of houses in comparison to the existing number, and then further compare this to the number of houses that other towns in the local area have been asked to accommodate. It will dramatically compound already existing problems with regards to traffic congestion, pollution, and access to local amenities, and furthermore has the potential to destroy a charming town centre. I support careful, well thought out development that will enhance the local area, but what is being proposed is far removed from this and cannot be a good thing.