Local Plan 2011-2031 Proposed Submission Draft

I wish to put forward my views on why the plan is unsound; my legal understanding is insufficient to comment on the legality.
In particular, it is the large development of 2800 homes to the north of Baldock (site BA1) that concerns me.
The plan is UNSOUND because it allocates a disproportionate number of new homes to the smallest of the towns in North Herts, when few of the new population will have or obtain jobs in the town, but commute to Stevenage, Cambridge or London. There are few higher paid jobs in Baldock apart from the doctors and legal practices, whereas Stevenage is a major centre for growth industries such as aerospace and pharmaceuticals. Jobs of this type will not come to small industrial units of the type envisaged by the plan along the Cambridge road. The largest developments in Hertfordshire should be matched to the locations of employment growth, which are not in Baldock but in Stevenage and Welwyn Garden City.
The plan is UNSOUND because it greatly increases the size of the town without properly connecting it to the rest of Baldock. Proper connection was achieved with the development at Clothall Common, and placement of the Primary school between old and new portions of the town worked well to integrate the population. Access from Clothall Common by foot, car and bicycle is possible along a range of relatively short routes and none is congested. Despite this relatively good infrastructure connectivity and the rather smaller size of the development even there integration socially took some time.
The proposed site BA1 only touches the existing town at one end and extends much further from the town centre. It seems to be planned that it will have its own schools, leading to this new area being simultaneously part of Baldock and quite separate because children will not go to the same school. The railway will be a permanent barrier to movement, and the proposed link road will hardly help if it makes people first leave the town to the East before they start heading into the town past the already clogged junction of Station Road and Whitehorse Street. Many will take the shorter route, whether they are going into the town or to the adjacent parts of Letchworth, which generate car journeys for Baldock residents to visit Sainsbury and adjacent retail outlets, as well as the recycling centre.
The plan is UNSOUND because the infrastructure proposed will not work for the residents and making it work well would impose unacceptable costs. In fact the documentation presented acknowledges that there are significant unknowns even to do the minimum, associated with railway crossings and utility upgrades to allow Baldock's electrical, gas, water and sewage services to cope. (WYG Appraisal Report dated 11th November 2014)
It is impossible to increase the capacity of the key junction of Station Road and Whitehorse Street without demolishing the listed buildings surrounding it. Similarly, the railway bridge itself is already a problem for pedestrians with its narrow footpaths and for cyclists who are held up by the usual mixture of vehicles close to the kerb and vehicles close to the centre of the road. There is no room for a cycle lane. The junction for the station is complex and hazardous - I have myself been knocked off my bicycle by a vehicle whose driver just did not see me despite my high visibility yellow clothing and pulled out of the station approach as I was in front of her. The new pedestrian route crossing the railway would presumably deliver people to the top of the hill where Icknield Way meets the Royston road. This will not be a cycle friendly route into the town.
The proposed 'link road' is almost a bypass route through the new development and will be used by traffic heading East from the A1 northern junction. This type of link road (cf Biggleswade) will have numerous roundabouts and/or traffic calming and this will generate particulate emissions from the brakes and tyres of the vehicles using the route, even if they are powered electrically. A direct route from the A1 services to the Royston road roundabout with higher capacity would perhaps improve matters but it would be expensive and the 'internal' link road would still be needed to access BA1. However, it would allow heavy vehicles to be removed entirely from Station Road/North Road 'except for access'. The removal of heavy vehicles would require a new junction on the bypass allowing access from the bypass onto the Buntingford Road, but only for traffic from the Royston direction, and onto the bypass but only in the direction of Royston.
If development is imposed then these improved highway provisions should be imposed: direct trunk connection from the A1 services to the existing bypass and a new junction between Clothall Road and the existing bypass.
The plan is UNSOUND because the railway station is likely to remain of low capacity compared with Stevenage (large town, major interchange), Hitchin (moderate sized town and railway junction/interchange) and Letchworth (large town). If, as seems likely, the thousands of new homes are for people working in Stevenage, London or Cambridge then they should be in safe walking/cycling range of a high capacity railway station. Like most of the other considerations this suggests West of Stevenage as a better location, where multiple cycle routes cross the railway - and perhaps the Leisure Park should devote a little space from its car park to provide cycle racks.
In summary, the plan is UNSOUND because:
It provides housing disproportionate in quantity to the needs of Baldock.
It would lead to a new area that could not properly integrate with the existing town. (NPPF 23)
It will be neither a new centre with its own services and shops nor integrate with the historic town. (NPPF 23)
The infrastructure required to make it 'work' even with these problems is not likely to be provided. (NPPF 30, 124, 177)
Alternatives would place the housing close to where the work is; sustainable development must ensure that as far as possible people get to work on foot or by bicycle rather than placing additional loads on road and rail infrastructure. (NPPF 30)