Local Plan 2011-2031 Proposed Submission Draft

I wish to object to the Local Plan as I consider it NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.
General comments for the Baldock area (especially sites BA1/BA2/BA3)
Baldock is a small town and is ill-prepared for the high level of expansion that this proposed plan would entail. It is disproportionate that Baldock has such a high proportion of houses allocated compared to other towns in the area.
The sites around Clothall Common area (BA2/3) need to be treated as one site and a separate masterplan for the area to be prepared to consider fully the whole area. This must include additional doctors and schools to be in place as the first houses are completed. School places in particular are already a problem without any additional houses being built on any site in Baldock (when my daughter started school in 2014 many children were allocated schools outside Baldock as there were 32 too few places within Baldock).
"It is important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion" NPPF 177. The Council have failed to provide detailed plans, timescales or costings for the necessary infrastructure at any site and this gives no confidence that said infrastructure will be provided at the times it is needed, of a good quality, or even at all. Other developments in the area eg Great Ashby have discovered this to their cost.
All houses to be built should have room for at least 2 cars.
Suggested changes:
Reduce the housing allocation for Baldock and allocate some of this to other sites in the other towns in North Herts. Consider also an entirely new settlement elsewhere away from the 4 towns.
Treat all sites in Clothall Common area as one site and create master plan for the area to include doctors and schools.
All houses to be built should include parking for at least 2 vehicles.
Infrastructure planning and timescales should be in place before building starts; detailed investigations of all aspects (especially traffic) must be carried out for the plan to be approved.

Specific comments
Policies SP8 and SP14 - The proposed allocation of 2,800 homes at North of Baldock (site BA1)
1. This site is acknowledged by the council as making a significant contribution to Green Belt purposes (Housing and Green Belt background paper para 3.14)
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

2. Table 4 sustainability appraisal notes that this site creates a high probability of adverse impacts on landscape and townscape character and Landscape Sensitivity Study of July 2013 identifies the land north of Bygrave as having moderate to high landscape sensitivity. The Bygrave Road from Baldock has environmentally protected grass verges.
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

3. Baldock is situated in a valley and air pollutants are known to be trapped and concentrated in Baldock. The traffic levels in Hitchin Street and Whitehorse Street are already causing the level of pollutants to be in danger of exceeding EU permitted levels (para 9.28). The number of extra vehicles associated with the increased number of homes and services in and around Baldock will cause these levels to be surpassed and will affect the health of the people of Baldock (particularly with regard to respiratory disease). The Housing and Green Belt background paper notes that former site 209E (Priory Fields Hitchin) was considered unsuitable for exactly this reason.
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

4. The roads pose a major obstacle for this plan. The crossroads where Whitehorse Street, North Road, Clothall Road and Royston Road meet are heaving with traffic for much of the day. There are frequent queues. Almost all of the traffic coming through Baldock passes through this crossroads. There is no way to expand this crossroads because it has listed buildings on it. It is already the case that Raban Court has been hit several times by lorries turning left from North Road (A507) to Royston Road (B656).
Traffic coming to and from the station and the houses on Icknield Way East further impacts the pinch point at this junction. In addition the railway bridge over the A507 is hit frequently by lorries and this causes disruption on the roads while everything is cleared up. Delays also occur when lorries realise that they cannot fit under the bridge and have to perform manoeuvres to turn around.
The proposed miniroundabout at Whitehorse St / Station Rd crossroads, the only mitigation planned for Baldock (AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction.
The traffic on the A507 is constant and heavy especially in peak periods which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case.
Traffic modelling has not been carried out sufficiently to prepare for the potential impact of building so many houses on the BA1 site. With 2-3 vehicles projected per house and almost all people working outside Baldock (and many of them using the B656/A507 crossroads) the implication is that an extra 5000-7000 vehicles may be on our roads and many of those would be coming down to this already heavily congested junction. The proposed link roads will not reduce the pressure on this junction or other parts of Baldock enough. The junction of the High Street with Hitchin/Whitehorse Street is another part of Baldock where air pollution and traffic levels cause concern.
The Plan is NOT JUSTIFIED and NOT EFFECTIVE. There is insufficient evidence that the development can be achieved without a huge negative impact on the local highway network. This applies also in respect of BA4 and BA10 (SP8 and SP14). There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.
5. As most new Baldock residents will work outside Baldock the railway station would also need expanding to accept an 80% rise in commuters and the longer trains that would be needed. The current proposal (in consultation at the moment) to cut fast off-peak services to Baldock will not make Baldock desirable to people as a place to live.

The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on transport and local highway network. There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.

6. The Plan does not retain and enhance the town centre of Baldock as recommended by the NPPF (para 23). Building a new development BA1 on the other side of the railway line to the main part of town would divide the community and will cause traffic problems. "By designating Local Green Space, local communities will be able to rule out new development other than in very special circumstances". NHDC have decided to locate many sites including BA1 on Green Belt land going in the face of this policy. They have not provided appropriate justification for redesignating Green Belt land showing what "exceptional circumstances" there are that necessitates building on the Green Belt. Site BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as in NPPF chapter 9. "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use poorer areas of land in preference to that of a higher quality" (NPPF 112) - the land at BA1 is high quality land.

7. The provision of sewerage and potential risk of flooding over this vast site has not been fully investigated. The details of the protection of the Ivel Nature reserve are not clear; neither is it clear how other wildlife will be protected such as the endangered corn bunting on BA1.

8. Insufficient green spaces such as parks have been provided and there are no details of extra leisure facilities within Baldock.

The Plan is NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.

Suggested changes (site BA1):

* Reduce size of site to enable transport and community to cope
* More equitable distribution of houses across North Herts
* Reduce number/density of houses to reduce flood risk and protect wildlife
* Additional railway parking
* Additional town centre parking
* Require site to include at least two large children's play parks and parking to allow people to visit them.
* Require a minimum of green space per site to ensure improved air quality, surface water drainage, and general aesthetic wellbeing. Suggest developers imitate the % green space achieved in Milton Keynes, a highly successful build with regards to green spaces. 22% figure 1.7, pg 22 in the MK planning manual, MKDC 1992.
* Every house to have a back and front garden to aid water drainage and reduce flooding risk.
* Tree planting along every public road
* Ensure houses have sufficient parking (2 cars per house minimum)
* Build key infrastructure in advance of allowing new building (link road to ensure that construction traffic does not have to go through existing road network pinch points.)
* An additional large green space with ample parking to be provided as part of the new development in order that Baldock has a facility which can cater for both increased demand and the need to drive to its location.
* Plan to include sports facilities.
* Work in partnership with the rail companies and bus providers to ensure that services are increased as the size of the town grows rather than reduced (see Great Northern 2018 consultation). Increase the size and amenities of the station (i.e. more manned ticket office hours) in order that it can cater for the increased demand.

I wish to be kept informed about the plan.
I do not wish to appear at the oral examination.

I wish to object to the Local Plan as I consider it NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.
General comments for the Baldock area (especially sites BA1/BA2/BA3)
Baldock is a small town and is ill-prepared for the high level of expansion that this proposed plan would entail. It is disproportionate that Baldock has such a high proportion of houses allocated compared to other towns in the area.
The sites around Clothall Common area (BA2/3) need to be treated as one site and a separate masterplan for the area to be prepared to consider fully the whole area. This must include additional doctors and schools to be in place as the first houses are completed. School places in particular are already a problem without any additional houses being built on any site in Baldock (when my daughter started school in 2014 many children were allocated schools outside Baldock as there were 32 too few places within Baldock).
"It is important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion" NPPF 177. The Council have failed to provide detailed plans, timescales or costings for the necessary infrastructure at any site and this gives no confidence that said infrastructure will be provided at the times it is needed, of a good quality, or even at all. Other developments in the area eg Great Ashby have discovered this to their cost.
All houses to be built should have room for at least 2 cars.
Suggested changes:
Reduce the housing allocation for Baldock and allocate some of this to other sites in the other towns in North Herts. Consider also an entirely new settlement elsewhere away from the 4 towns.
Treat all sites in Clothall Common area as one site and create master plan for the area to include doctors and schools.
All houses to be built should include parking for at least 2 vehicles.
Infrastructure planning and timescales should be in place before building starts; detailed investigations of all aspects (especially traffic) must be carried out for the plan to be approved.

Specific comments
Policies SP8 and SP14 - The proposed allocation of 2,800 homes at North of Baldock (site BA1)
1. This site is acknowledged by the council as making a significant contribution to Green Belt purposes (Housing and Green Belt background paper para 3.14)
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

2. Table 4 sustainability appraisal notes that this site creates a high probability of adverse impacts on landscape and townscape character and Landscape Sensitivity Study of July 2013 identifies the land north of Bygrave as having moderate to high landscape sensitivity. The Bygrave Road from Baldock has environmentally protected grass verges.
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

3. Baldock is situated in a valley and air pollutants are known to be trapped and concentrated in Baldock. The traffic levels in Hitchin Street and Whitehorse Street are already causing the level of pollutants to be in danger of exceeding EU permitted levels (para 9.28). The number of extra vehicles associated with the increased number of homes and services in and around Baldock will cause these levels to be surpassed and will affect the health of the people of Baldock (particularly with regard to respiratory disease). The Housing and Green Belt background paper notes that former site 209E (Priory Fields Hitchin) was considered unsuitable for exactly this reason.
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

4. The roads pose a major obstacle for this plan. The crossroads where Whitehorse Street, North Road, Clothall Road and Royston Road meet are heaving with traffic for much of the day. There are frequent queues. Almost all of the traffic coming through Baldock passes through this crossroads. There is no way to expand this crossroads because it has listed buildings on it. It is already the case that Raban Court has been hit several times by lorries turning left from North Road (A507) to Royston Road (B656).
Traffic coming to and from the station and the houses on Icknield Way East further impacts the pinch point at this junction. In addition the railway bridge over the A507 is hit frequently by lorries and this causes disruption on the roads while everything is cleared up. Delays also occur when lorries realise that they cannot fit under the bridge and have to perform manoeuvres to turn around.
The proposed miniroundabout at Whitehorse St / Station Rd crossroads, the only mitigation planned for Baldock (AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction.
The traffic on the A507 is constant and heavy especially in peak periods which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case.
Traffic modelling has not been carried out sufficiently to prepare for the potential impact of building so many houses on the BA1 site. With 2-3 vehicles projected per house and almost all people working outside Baldock (and many of them using the B656/A507 crossroads) the implication is that an extra 5000-7000 vehicles may be on our roads and many of those would be coming down to this already heavily congested junction. The proposed link roads will not reduce the pressure on this junction or other parts of Baldock enough. The junction of the High Street with Hitchin/Whitehorse Street is another part of Baldock where air pollution and traffic levels cause concern.
The Plan is NOT JUSTIFIED and NOT EFFECTIVE. There is insufficient evidence that the development can be achieved without a huge negative impact on the local highway network. This applies also in respect of BA4 and BA10 (SP8 and SP14). There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.
5. As most new Baldock residents will work outside Baldock the railway station would also need expanding to accept an 80% rise in commuters and the longer trains that would be needed. The current proposal (in consultation at the moment) to cut fast off-peak services to Baldock will not make Baldock desirable to people as a place to live.

The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on transport and local highway network. There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.

6. The Plan does not retain and enhance the town centre of Baldock as recommended by the NPPF (para 23). Building a new development BA1 on the other side of the railway line to the main part of town would divide the community and will cause traffic problems. "By designating Local Green Space, local communities will be able to rule out new development other than in very special circumstances". NHDC have decided to locate many sites including BA1 on Green Belt land going in the face of this policy. They have not provided appropriate justification for redesignating Green Belt land showing what "exceptional circumstances" there are that necessitates building on the Green Belt. Site BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as in NPPF chapter 9. "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use poorer areas of land in preference to that of a higher quality" (NPPF 112) - the land at BA1 is high quality land.

7. The provision of sewerage and potential risk of flooding over this vast site has not been fully investigated. The details of the protection of the Ivel Nature reserve are not clear; neither is it clear how other wildlife will be protected such as the endangered corn bunting on BA1.

8. Insufficient green spaces such as parks have been provided and there are no details of extra leisure facilities within Baldock.

The Plan is NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.

Suggested changes (site BA1):

* Reduce size of site to enable transport and community to cope
* More equitable distribution of houses across North Herts
* Reduce number/density of houses to reduce flood risk and protect wildlife
* Additional railway parking
* Additional town centre parking
* Require site to include at least two large children's play parks and parking to allow people to visit them.
* Require a minimum of green space per site to ensure improved air quality, surface water drainage, and general aesthetic wellbeing. Suggest developers imitate the % green space achieved in Milton Keynes, a highly successful build with regards to green spaces. 22% figure 1.7, pg 22 in the MK planning manual, MKDC 1992.
* Every house to have a back and front garden to aid water drainage and reduce flooding risk.
* Tree planting along every public road
* Ensure houses have sufficient parking (2 cars per house minimum)
* Build key infrastructure in advance of allowing new building (link road to ensure that construction traffic does not have to go through existing road network pinch points.)
* An additional large green space with ample parking to be provided as part of the new development in order that Baldock has a facility which can cater for both increased demand and the need to drive to its location.
* Plan to include sports facilities.
* Work in partnership with the rail companies and bus providers to ensure that services are increased as the size of the town grows rather than reduced (see Great Northern 2018 consultation). Increase the size and amenities of the station (i.e. more manned ticket office hours) in order that it can cater for the increased demand.

I wish to be kept informed about the plan.
I do not wish to appear at the oral examination.

I wish to object to the Local Plan as I consider it NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.
General comments for the Baldock area (especially sites BA1/BA2/BA3)
Baldock is a small town and is ill-prepared for the high level of expansion that this proposed plan would entail. It is disproportionate that Baldock has such a high proportion of houses allocated compared to other towns in the area.
The sites around Clothall Common area (BA2/3) need to be treated as one site and a separate masterplan for the area to be prepared to consider fully the whole area. This must include additional doctors and schools to be in place as the first houses are completed. School places in particular are already a problem without any additional houses being built on any site in Baldock (when my daughter started school in 2014 many children were allocated schools outside Baldock as there were 32 too few places within Baldock).
"It is important to ensure that there is a reasonable prospect that planned infrastructure is deliverable in a timely fashion" NPPF 177. The Council have failed to provide detailed plans, timescales or costings for the necessary infrastructure at any site and this gives no confidence that said infrastructure will be provided at the times it is needed, of a good quality, or even at all. Other developments in the area eg Great Ashby have discovered this to their cost.
All houses to be built should have room for at least 2 cars.
Suggested changes:
Reduce the housing allocation for Baldock and allocate some of this to other sites in the other towns in North Herts. Consider also an entirely new settlement elsewhere away from the 4 towns.
Treat all sites in Clothall Common area as one site and create master plan for the area to include doctors and schools.
All houses to be built should include parking for at least 2 vehicles.
Infrastructure planning and timescales should be in place before building starts; detailed investigations of all aspects (especially traffic) must be carried out for the plan to be approved.

Specific comments
Policies SP8 and SP14 - The proposed allocation of 2,800 homes at North of Baldock (site BA1)
1. This site is acknowledged by the council as making a significant contribution to Green Belt purposes (Housing and Green Belt background paper para 3.14)
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

2. Table 4 sustainability appraisal notes that this site creates a high probability of adverse impacts on landscape and townscape character and Landscape Sensitivity Study of July 2013 identifies the land north of Bygrave as having moderate to high landscape sensitivity. The Bygrave Road from Baldock has environmentally protected grass verges.
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

3. Baldock is situated in a valley and air pollutants are known to be trapped and concentrated in Baldock. The traffic levels in Hitchin Street and Whitehorse Street are already causing the level of pollutants to be in danger of exceeding EU permitted levels (para 9.28). The number of extra vehicles associated with the increased number of homes and services in and around Baldock will cause these levels to be surpassed and will affect the health of the people of Baldock (particularly with regard to respiratory disease). The Housing and Green Belt background paper notes that former site 209E (Priory Fields Hitchin) was considered unsuitable for exactly this reason.
The Plan is NOT JUSTIFIED as it is not the most appropriate strategy.

4. The roads pose a major obstacle for this plan. The crossroads where Whitehorse Street, North Road, Clothall Road and Royston Road meet are heaving with traffic for much of the day. There are frequent queues. Almost all of the traffic coming through Baldock passes through this crossroads. There is no way to expand this crossroads because it has listed buildings on it. It is already the case that Raban Court has been hit several times by lorries turning left from North Road (A507) to Royston Road (B656).
Traffic coming to and from the station and the houses on Icknield Way East further impacts the pinch point at this junction. In addition the railway bridge over the A507 is hit frequently by lorries and this causes disruption on the roads while everything is cleared up. Delays also occur when lorries realise that they cannot fit under the bridge and have to perform manoeuvres to turn around.
The proposed miniroundabout at Whitehorse St / Station Rd crossroads, the only mitigation planned for Baldock (AECOM technical note para 5.1, Draft report of North Herts Local Plan Model Testing Table 5.1) may reduce accidents between vehicles but will not reduce time spent and congestion caused by this junction.
The traffic on the A507 is constant and heavy especially in peak periods which extend over at least two hours and are worst in school term time. It also increases any time of day or night if there is a crisis on the A1. The A507 is not shown as a "key feature to transport in North Herts" IDP (para 5.4) despite being now arguably the busiest road through the town. A survey of all Baldock roads at the time of the Bypass inquiry showed that this would be the case.
Traffic modelling has not been carried out sufficiently to prepare for the potential impact of building so many houses on the BA1 site. With 2-3 vehicles projected per house and almost all people working outside Baldock (and many of them using the B656/A507 crossroads) the implication is that an extra 5000-7000 vehicles may be on our roads and many of those would be coming down to this already heavily congested junction. The proposed link roads will not reduce the pressure on this junction or other parts of Baldock enough. The junction of the High Street with Hitchin/Whitehorse Street is another part of Baldock where air pollution and traffic levels cause concern.
The Plan is NOT JUSTIFIED and NOT EFFECTIVE. There is insufficient evidence that the development can be achieved without a huge negative impact on the local highway network. This applies also in respect of BA4 and BA10 (SP8 and SP14). There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.
5. As most new Baldock residents will work outside Baldock the railway station would also need expanding to accept an 80% rise in commuters and the longer trains that would be needed. The current proposal (in consultation at the moment) to cut fast off-peak services to Baldock will not make Baldock desirable to people as a place to live.

The Plan is NOT EFFECTIVE as it cannot be achieved without considerable negative effect on transport and local highway network. There is no adequate Transport Assessment or Transport Statement and the Plan is therefore NOT CONSISTENT WITH NATIONAL POLICY.

6. The Plan does not retain and enhance the town centre of Baldock as recommended by the NPPF (para 23). Building a new development BA1 on the other side of the railway line to the main part of town would divide the community and will cause traffic problems. "By designating Local Green Space, local communities will be able to rule out new development other than in very special circumstances". NHDC have decided to locate many sites including BA1 on Green Belt land going in the face of this policy. They have not provided appropriate justification for redesignating Green Belt land showing what "exceptional circumstances" there are that necessitates building on the Green Belt. Site BA1 is acknowledged by the Council as making a significant contribution to Green Belt purposes as in NPPF chapter 9. "Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use poorer areas of land in preference to that of a higher quality" (NPPF 112) - the land at BA1 is high quality land.

7. The provision of sewerage and potential risk of flooding over this vast site has not been fully investigated. The details of the protection of the Ivel Nature reserve are not clear; neither is it clear how other wildlife will be protected such as the endangered corn bunting on BA1.

8. Insufficient green spaces such as parks have been provided and there are no details of extra leisure facilities within Baldock.

The Plan is NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY.

Suggested changes (site BA1):

* Reduce size of site to enable transport and community to cope
* More equitable distribution of houses across North Herts
* Reduce number/density of houses to reduce flood risk and protect wildlife
* Additional railway parking
* Additional town centre parking
* Require site to include at least two large children's play parks and parking to allow people to visit them.
* Require a minimum of green space per site to ensure improved air quality, surface water drainage, and general aesthetic wellbeing. Suggest developers imitate the % green space achieved in Milton Keynes, a highly successful build with regards to green spaces. 22% figure 1.7, pg 22 in the MK planning manual, MKDC 1992.
* Every house to have a back and front garden to aid water drainage and reduce flooding risk.
* Tree planting along every public road
* Ensure houses have sufficient parking (2 cars per house minimum)
* Build key infrastructure in advance of allowing new building (link road to ensure that construction traffic does not have to go through existing road network pinch points.)
* An additional large green space with ample parking to be provided as part of the new development in order that Baldock has a facility which can cater for both increased demand and the need to drive to its location.
* Plan to include sports facilities.
* Work in partnership with the rail companies and bus providers to ensure that services are increased as the size of the town grows rather than reduced (see Great Northern 2018 consultation). Increase the size and amenities of the station (i.e. more manned ticket office hours) in order that it can cater for the increased demand.

I wish to be kept informed about the plan.
I do not wish to appear at the oral examination.