Local Plan 2011-2031 Proposed Submission Draft

I wish to object to the proposed development at the Blackhorse Farm site BA1 to the north of Baldock as it is NOT JUSTIFIED, NOT EFFECTIVE and NOT CONSISTENT WITH NATIONAL POLICY in the following areas:

* Inappropriate Green Belt development
* Air quality in town centre.
* Traffic congestion in Baldock town centre
* Capacity restrictions at Baldock Station

Additional details on why I believe each of these points are an issue are provided below.

1. Inappropriate Green Belt development: The proposed Blackhorse Farm development is in direct contravention to clearly-stated government policy in relation to the Green Belt. The Department for Communities and Local Government's planning guidance states that:

"The Government attaches great importance to Green Belts. The fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open ... inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in very special circumstances."

NHDC councillors have stated that they have no other option than to propose green belt developments in order to meet government housing targets, but the ministerial guidance on Green Belt development published on 6th October 2014 makes it clear that councils are NOT required to build on the Green Belt in order to meet housing targets.

The Blackhorse Farm development is clearly urbanisation of land, and political expediency does not constitute "very special circumstances". This is exactly the kind of inappropriate development that the Green Belt is intended to stop.

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) on this basis the plan not the most appropriate strategy.

1. Air quality in town centre: Baldock sits in a valley which is well known for having poor air circulation causing air pollutants from vehicle emissions to be trapped and concentrated. With the he Eastern Baldock Bypass was built in 2003, following intervention in parliament by Sir Oliver Heald MP, to alleviate this pollution.

Since then asthma amongst 5-16 year olds has reduced from 15% (in 1994) to 6%. However traffic is on the increase and now the levels pollutants in Hitchin St and Whitehorse St are in danger of exceeding EU permitted levels. The Housing and Green Belt background paper notes that former site 209E (Priory Fields Hitchin) was considered unsuitable for exactly this reason.

The extra vehicles, domestic and service vehicles, which will arise from the building of 3,590 new homes, a significant proportion of which will travel through and around Baldock will tip the balance and affect the health of all residents especially the very young, the old, pedestrians and cyclists raising health problems such as respiratory disease, cardiac problems and even cancer. As a parent and resident of Baldock who lives just off Hitchin Street this is deeply concerning.

2. Traffic congestion in Baldock town centre: The local highways network will be severely affected by the development of this site. Primarily of concern is the junction where the A507 North Road meets the Royston Road (the old route of the A505) at the junction of Whitehorse Street, Station Road, Royston Road and Clothall Road.

All 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.

There are listed buildings on either side of the junction so development of this junction to cope with additional traffic will be a problem. So building 2,800 houses on the Blackhorse Farm site is about the worst possible thing that could happen in this part of Baldock.

Therefore the A507 from the traffic lights to the A1 roundabout is not a suitable road to give access to a new development at BA1 as NHDC plans. It is very likely, since there are few work opportunities in Baldock that most of the residents will commute to other parts of North Herts, Bedfordshire and Cambridgeshire using this junction as well as the proposed new link roads.

3. Capacity restrictions at Baldock Station: In relation to the NPF, Section 4 "Promoting sustainable transport". Paragraph 32 states that "All developments the generate significant amounts of movement should be supported by a Transport Statement ..." and goes on to state that "... development decisions should take account of whether improvements can be undertaken within the transport network that cost effectively limit significant impacts of development. "

The NHDC Local Plan makes no significant points other than the convenience of Baldock's location next to a station. It is interesting to note that NHDC had not consulted with Govia the train provider during the course of the preparation of this local plan. Currently Govia are planning to reduce the service to Baldock at off-peak times.

Therefore the Plan is not effective as it cannot be delivered in the plan period. It also fails the consistency with national policy test as it does not properly assess the transport improvements that would be needed for the BA1 site to work.

If this proposed development goes ahead it is expected that most new Baldock residents will commute to work outside Baldock. In addition to extra pressure on the roads there will be unacceptable pressure on the already overcrowded railway service. Baldock station is small and would require significant alteration to accommodate additional passengers and the longer trains needed for them.

The train operator (Govia) is currently holding their own consultation on future rail provision for the line and intend to cut "semi-fast" trains stopping at Baldock outside of peak hours. This will not be sufficient serve the thousands of extra journeys that will be made from Baldock. More concerning is that until recently both British Rail and Goiva has not been consulted by NHDC in relation to the local plan in relation to important issues such as building a bridge over the railway from the A505 Royston road into or round the BA1 site or the potential of additional demand in the future.

There is no information on deliverability or cost of this proposed road / railway crossing which will be very expensive if it is to be delivered without visual impacts. It is quite exposed at this point. This indicates that NHDC has produced a poor plan without much forward planning and appreciation of all the related infrastructure required.

Baldock - Sites BA2, BA3, BA4 & BA5:

There appears to be insufficient linked up planning in relation to the proposed sites for development other than BA1 (i.e. BA2, BA3, BA4 and BA5) in Baldock which could account for an additional 520 houses all located around Clothall Common in Baldock. The 2011 Census has 4491 dwellings within the town, when combined these four developments constitute an expansion of 11.5% on the figures at that time. It has to be expected that these sites will bring additional pressure on the current roads, rail links, schools, doctors surgery and other amenities such as the community centre, library and town centre parking. However as the local plan splits these sites into separate smaller developments there is no mention of providing additional school/doctor services to cater for the additional demand this will bring to local infrastructure and amenities.

The introduction to the local plan states that "Strategic Housing Sites (defined as sites of 500 or more
homes) which will make a substantial contribution towards housing requirements over the plan period." As such the plan must combine BA2, BA3, BA4 and BA5 into one larger development and as treat it as a separate Strategic Housing Site.