Local Plan 2011-2031 Proposed Submission Draft

First, the plan is not justified as it does not present the most appropriate strategy for the distribution of housing, given the detrimental effects on Baldock of the proposed scale of growth; in particular the acknowledged negative impacts of site BA1, serious questions about its deliverability, the fact that it is not proposed for early release, and the availability of alternative sites that do not appear to have such significant drawbacks:
1. Impacts: the plan and its supporting documents acknowledge that site BA1 would have several adverse impacts:
a) Although Green Belt land will need to be released to meet North Hertfordshire's housing requirements, 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);
b) The sustainability appraisal notes (Table 9) that this site, along with the others proposed for the edges of Baldock, creates a high probability of adverse impacts on landscape and townscape character - with the Landscape Sensitivity Study (July 2013) identifying the land north of Bygrave Road having moderate to high landscape sensitivity;
c) Increased traffic arising from this scale of development is likely to breach air quality standards in the Whitehorse St/Hitchin St areas, which the plan notes are already close to being exceeded in these locations (para. 9.28). The Housing and Green Belt Background Paper notes that former site 209E (Priory Fields, Hitchin) was considered unsuitable for allocation for precisely this reason;
d) The site is highly likely to impose severe and unsustainable pressure on the local highways network, for reasons set out below;
e) Development would be difficult to integrate effectively with the rest of Baldock, due to the extent to which the railway line creates a hard barrier with limited existing or potential crossing points;
2. Deliverability: there are serious questions about whether this site is deliverable without unacceptable highways impacts, and whether it is viable. This is covered under whether the proposals are effective (below).
3. Phasing and availability of alternative sites: the proposed release of this and the other strategic sites from the Green Belt is justified by the Council partly on the basis of its ability to contribute to meeting housing requirements "in the first five years following adoption of the plan" (Housing and Green Belt Background Paper, para. 5.52). However the plan itself is clear that other proposed sites at Baldock would be developed first. This fact also undermines the rationale for allocating site BA1 in preference to land at Stevenage West, which is proposed to be safeguarded for future development for up to 3,100 homes rather than being released during the plan period (Policy SP8). Land at Stevenage West could be allocated to meet housing needs in a way that does not have the range of adverse impacts associated with BA1, and which would be closer to main centres of employment, retail and public transport.

Second, the plan is not effective, because it is very unlikely that the scale of growth proposed for Baldock can be achieved without an overwhelming negative effect on the local highway network, but insufficient evidence has been provided about the highways impacts and the potential effectiveness and viability of the suggested mitigation measures. As a result there can be no confidence that the plan's proposals for Baldock are deliverable:
1. Baldock is a historic town with a medieval street pattern at its core. The plan acknowledges (13.29) that the Whitehorse Street/Royston Road crossroads is a key pinch point. Both it and Station Road/North Road already suffer from congestion and long queues both peak and off-peak, with the narrow width of the railway bridge also inhibiting easy pedestrian and cycle connections from north to south. AECOM's technical note identifies the crossroads and Letchworth Gate as problem junctions (above capacity, unacceptable queuing) by 2013 even without further development (table 4.1).
2. The proposed allocations for residential and employment development in Baldock will generate a significant increase in trips through the Whitehorse St/Royston Rd crossroads due to:
a) The high proportion of trips from site BA1 (North of Baldock) that are likely to be towards Letchworth and Hitchin. The plan stresses how interconnected these towns are for movement (paras. 2.31, 4.27, 13.14), and that many new residents will commute out (paras. 4.25-6).
b) The way the employment allocation (policy SP3) deliberately 'over-provides' for the needs of the town, even on its expanded basis (paras 4.25-6), which is likely to lead to more peak hour trips between Baldock, Letchworth and Hitchin.
c) The fact that the proposed link road through BA1 would involve a long round trip to Letchworth/Hitchin for most residents of the site, rather than following natural desire lines. Experience following the opening of the Baldock bypass shows that a lot of traffic follows the shortest route rather than the least congested.
3. The plan acknowledges (4.179) that "not all" traffic from Blackhorse Farm will have to use the Whitehorse St/Royston Rd crossroads - so it is clear the Council accept that at least a proportion of it will.
4. However there has not been adequate modelling of these impacts. It is only this year that AECOM's transport model has been extended to Baldock. While it identifies the crossroads and Letchworth Gate as problem junctions by 2031 even without development (table 4.1), it makes clear that it does not attempt to identify specific highways impacts of the proposed developments, or their dependency on new infrastructure (section 7 of AECOM's note); it has not modelled the effect of the proposed new highways links; it provides no assessment of post-mitigation impacts; and no information is given about the sole mitigation measure proposed within the town (mini roundabout and signal optimisation of the Whitehorse St/Royston Rd crossroads). We have seen separate modelling work undertaken for the promoters of the site - Hertfordshire County Council - by White Young Green, which appears to underestimate the extent to which trips are likely to use the crossroads, especially as it looks solely at the proposed residential developments and not the employment allocation as well.
5. It is clear, therefore, that the is a high probability that the highway network in the centre of Baldock would be unable to cope with the level of development proposed, but insufficient work has been done on behalf of the Council to assess the deliverability and impact of mitigation measures. As the plan's single largest site relies in part on this local road network functioning, there can be no confidence that this aspect of the plan is deliverable, or indeed that the overall scale of growth planned for Baldock can be accommodated in highways terms.
6. Nor does it appear that the financial viability of the proposed mitigation measures has been tested fully, especially if a new crossing of the railway is to be delivered without unacceptable visual impacts, and without prohibitive costs being imposed by Network Rail. The Local Plan Viability Assessment (Update, August 2016) has only taken an indicative approach to assessing the potential viability of the major sites, rather than looking at the specific infrastructure pressures and mitigation measures associated with each.

Third, the plan is not consistent with national policy. While the National Planning Policy Framework is clear that the evidence base for plans should be proportionate, it is equally clear that plans should identify whether transport improvements can be made to limit the significant impacts of development, and that where the residual cumulative impacts are severe there may be a case for preventing development (para. 32).

The Proposed Submission Local Plan does not satisfy this test. As set out above, it's very clear that the full impact of the scale of development proposed for Baldock, or of individual major site proposals, has not been properly assessed, with no information available on the impact and viability of the proposed mitigation measures.

This applies not only to site BA1, but also to the other major sites: for example, the plan mentions a new "southern link road" in relation to sites BA3 and BA4, but no further information to explain its route, viability or impact is provided in the plan or supporting documents.

The Odyssey Markides technical note for the Council asserts (para. 1.5) that "there are no issues that have emerged from the transport modelling work that... would cause a significant highway issue that cannot be resolved through appropriate mitigation measures". This conclusion is fundamentally flawed, resting as it does only on the wholly inadequate transport modelling work that has been undertaken.

First, the plan is not justified as it does not present the most appropriate strategy for the distribution of housing, given the acknowledged negative impacts of site BA1, serious questions about its deliverability, the fact that it is not proposed for early release, and the availability of alternative sites that do not appear to have such significant drawbacks:
1. Impacts: the plan and its supporting documents acknowledge that site BA1 would have several adverse impacts:
a) Although Green Belt land will need to be released to meet North Hertfordshire's housing requirements, 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);
b) The sustainability appraisal notes (Table 9) that this site, along with the others proposed for the edges of Baldock, creates a high probability of adverse impacts on landscape and townscape character - with the Landscape Sensitivity Study (July 2013) identifying the land north of Bygrave Road having moderate to high landscape sensitivity;
c) Increased traffic arising from this scale of development is likely to breach air quality standards in the Whitehorse St/Hitchin St areas, which the plan notes are already close to being exceeded in these locations (para. 9.28). The Housing and Green Belt Background Paper notes that former site 209E (Priory Fields, Hitchin) was considered unsuitable for allocation for precisely this reason;
d) The site is highly likely to impose severe and unsustainable pressure on the local highways network, for reasons set out below;
e) Development would be difficult to integrate effectively with the rest of Baldock, due to the extent to which the railway line creates a hard barrier with limited existing or potential crossing points;
2. Deliverability: there are serious questions about whether this site is deliverable without unacceptable highways impacts, and whether it is viable. This is covered under whether the proposals are effective (below).
3. Phasing and availability of alternative sites: the proposed release of this and the other strategic sites from the Green Belt is justified by the Council partly on the basis of its ability to contribute to meeting housing requirements "in the first five years following adoption of the plan" (Housing and Green Belt Background Paper, para. 5.52). However the plan itself is clear that other proposed sites at Baldock would be developed first. This fact also undermines the rationale for allocating site BA1 in preference to land at Stevenage West, which is proposed to be safeguarded for future development for up to 3,100 homes rather than being released during the plan period (Policy SP8). Land at Stevenage West could be allocated to meet housing needs in a way that does not have the range of adverse impacts associated with BA1, and which would be closer to main centres of employment, retail and public transport.

Second, the plan is not effective, because it is very unlikely that the scale of growth proposed for Baldock, and on this site in particular, can be achieved without an overwhelming negative effect on the local highway network, but insufficient evidence has been provided about the highways impacts and the potential effectiveness and viability of the suggested mitigation measures. As a result there can be no confidence that the plan's proposals for Baldock are deliverable:
1. Baldock is a historic town with a medieval street pattern at its core. The plan acknowledges (13.29) that the Whitehorse Street/Royston Road crossroads is a key pinch point. Both it and Station Road/North Road already suffer from congestion and long queues both peak and off-peak, with the narrow width of the railway bridge also inhibiting easy pedestrian and cycle connections from north to south. AECOM's technical note identifies the crossroads and Letchworth Gate as problem junctions (above capacity, unacceptable queuing) by 2013 even without further development (table 4.1).
2. The proposed allocations for residential and employment development in Baldock will generate a significant increase in trips through the Whitehorse St/Royston Rd crossroads due to:
a) The high proportion of trips from site BA1 (North of Baldock) that are likely to be towards Letchworth and Hitchin. The plan stresses how interconnected these towns are for movement (paras. 2.31, 4.27, 13.14), and that many new residents will commute out (paras. 4.25-6).
b) The way the employment allocation (policy SP3) deliberately 'over-provides' for the needs of the town, even on its expanded basis (paras 4.25-6), which is likely to lead to more peak hour trips between Baldock, Letchworth and Hitchin.
c) The fact that the proposed link road through BA1 would involve a long round trip to Letchworth/Hitchin for most residents of the site, rather than following natural desire lines. Experience following the opening of the Baldock bypass shows that a lot of traffic follows the shortest route rather than the least congested.
3. The plan acknowledges (4.179) that "not all" traffic from site BA1 will have to use the Whitehorse St/Royston Rd crossroads - so it is clear the Council accept that at least a proportion of it will.
4. However there has not been adequate modelling of these impacts. It is only this year that AECOM's transport model has been extended to Baldock. While it identifies the crossroads and Letchworth Gate as problem junctions by 2031 even without development (table 4.1), it makes clear that it does not attempt to identify specific highways impacts of the proposed developments, or their dependency on new infrastructure (section 7 of AECOM's note); it has not modelled the effect of the proposed new highways links; it provides no assessment of post-mitigation impacts; and no information is given about the sole mitigation measure proposed within the town (mini roundabout and signal optimisation of the Whitehorse St/Royston Rd crossroads). We have seen separate modelling work undertaken for the promoters of the site - Hertfordshire County Council - by White Young Green, which appears to underestimate the extent to which trips are likely to use the crossroads, especially as it looks solely at the proposed residential developments and not the employment allocation as well.
5. It is clear, therefore, that the is a high probability that the highway network in the centre of Baldock would be unable to cope with the level of development proposed, but insufficient work has been done on behalf of the Council to assess the deliverability and impact of mitigation measures. As the plan's single largest site relies in part on this local road network functioning, there can be no confidence that this aspect of the plan is deliverable, or indeed that the overall scale of growth planned for Baldock can be accommodated in highways terms.
6. Nor does it appear that the financial viability of the proposed mitigation measures has been tested fully, especially if a new crossing of the railway is to be delivered without unacceptable visual impacts, and without prohibitive costs being imposed by Network Rail. The Local Plan Viability Assessment (Update, August 2016) has only taken an indicative approach to assessing the potential viability of the major sites, rather than looking at the specific infrastructure pressures and mitigation measures associated with each.

Third, the plan is not consistent with national policy. While the National Planning Policy Framework is clear that the evidence base for plans should be proportionate, it is equally clear that plans should identify whether transport improvements can be made to limit the significant impacts of development, and that where the residual cumulative impacts are severe there may be a case for preventing development (para. 32).

The Proposed Submission Local Plan does not satisfy this test. As set out above, it's very clear that the full impact of the scale of development proposed for Baldock, or of individual major site proposals, has not been properly assessed, with no information available on the impact and viability of the proposed mitigation measures.

The Odyssey Markides technical note for the Council asserts (para. 1.5) that "there are no issues that have emerged from the transport modelling work that... would cause a significant highway issue that cannot be resolved through appropriate mitigation measures". This conclusion is fundamentally flawed, resting as it does only on the wholly inadequate transport modelling work that has been undertaken.

First, the plan is not justified as it does not present the most appropriate strategy for the distribution of housing, with too large a number allocated to Baldock - in particular given the acknowledged negative impacts of site BA1, serious questions about its deliverability, the fact that it is not proposed for early release, and the availability of alternative sites that do not appear to have such significant drawbacks:
1. Impacts: the plan and its supporting documents acknowledge that site BA1 would have several adverse impacts:
a) Although Green Belt land will need to be released to meet North Hertfordshire's housing requirements, 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);
b) The sustainability appraisal notes (Table 9) that this site, along with the others proposed for the edges of Baldock, creates a high probability of adverse impacts on landscape and townscape character - with the Landscape Sensitivity Study (July 2013) identifying the land north of Bygrave Road having moderate to high landscape sensitivity;
c) Increased traffic arising from this scale of development is likely to breach air quality standards in the Whitehorse St/Hitchin St areas, which the plan notes are already close to being exceeded in these locations (para. 9.28). The Housing and Green Belt Background Paper notes that former site 209E (Priory Fields, Hitchin) was considered unsuitable for allocation for precisely this reason;
d) The site is highly likely to impose severe and unsustainable pressure on the local highways network, for reasons set out below;
e) Development would be difficult to integrate effectively with the rest of Baldock, due to the extent to which the railway line creates a hard barrier with limited existing or potential crossing points;
2. Deliverability: there are serious questions about whether this site is deliverable without unacceptable highways impacts, and whether it is viable. This is covered under whether the proposals are effective (below).
3. Phasing and availability of alternative sites: the proposed release of this and the other strategic sites from the Green Belt is justified by the Council partly on the basis of its ability to contribute to meeting housing requirements "in the first five years following adoption of the plan" (Housing and Green Belt Background Paper, para. 5.52). However the plan itself is clear that other proposed sites at Baldock would be developed first. This fact also undermines the rationale for allocating site BA1 in preference to land at Stevenage West, which is proposed to be safeguarded for future development for up to 3,100 homes rather than being released during the plan period (Policy SP8). Land at Stevenage West could be allocated to meet housing needs in a way that does not have the range of adverse impacts associated with BA1, and which would be closer to main centres of employment, retail and public transport.

Second, the plan is not effective, because it is very unlikely that the scale of growth proposed for Baldock can be achieved without an overwhelming negative effect on the local highway network, but insufficient evidence has been provided about the highways impacts and the potential effectiveness and viability of the suggested mitigation measures. As a result there can be no confidence that the plan's proposals for Baldock are deliverable:
1. Baldock is a historic town with a medieval street pattern at its core. The plan acknowledges (13.29) that the Whitehorse Street/Royston Road crossroads is a key pinch point. Both it and Station Road/North Road already suffer from congestion and long queues both peak and off-peak, with the narrow width of the railway bridge also inhibiting easy pedestrian and cycle connections from north to south. AECOM's technical note identifies the crossroads and Letchworth Gate as problem junctions (above capacity, unacceptable queuing) by 2013 even without further development (table 4.1).
2. The proposed allocations for residential and employment development in Baldock will generate a significant increase in trips through the Whitehorse St/Royston Rd crossroads due to:
a) The high proportion of trips from site BA1 (North of Baldock) that are likely to be towards Letchworth and Hitchin. The plan stresses how interconnected these towns are for movement (paras. 2.31, 4.27, 13.14), and that many new residents will commute out (paras. 4.25-6).
b) The way the employment allocation (policy SP3) deliberately 'over-provides' for the needs of the town, even on its expanded basis (paras 4.25-6), which is likely to lead to more peak hour trips between Baldock, Letchworth and Hitchin.
c) The fact that the proposed link road through BA1 would involve a long round trip to Letchworth/Hitchin for most residents of the site, rather than following natural desire lines. Experience following the opening of the Baldock bypass shows that a lot of traffic follows the shortest route rather than the least congested.
3. The plan acknowledges (4.179) that "not all" traffic from site BA1 will have to use the Whitehorse St/Royston Rd crossroads - so it is clear the Council accept that at least a proportion of it will.
4. However there has not been adequate modelling of these impacts. It is only this year that AECOM's transport model has been extended to Baldock. While it identifies the crossroads and Letchworth Gate as problem junctions by 2031 even without development (table 4.1), it makes clear that it does not attempt to identify specific highways impacts of the proposed developments, or their dependency on new infrastructure (section 7 of AECOM's note); it has not modelled the effect of the proposed new highways links; it provides no assessment of post-mitigation impacts; and no information is given about the sole mitigation measure proposed within the town (mini roundabout and signal optimisation of the Whitehorse St/Royston Rd crossroads). We have seen separate modelling work undertaken for the promoters of the site - Hertfordshire County Council - by White Young Green, which appears to underestimate the extent to which trips are likely to use the crossroads, especially as it looks solely at the proposed residential developments and not the employment allocation as well.
5. It is clear, therefore, that the is a high probability that the highway network in the centre of Baldock would be unable to cope with the level of development proposed, but insufficient work has been done on behalf of the Council to assess the deliverability and impact of mitigation measures. As the plan's single largest site relies in part on this local road network functioning, there can be no confidence that this aspect of the plan is deliverable, or indeed that the overall scale of growth planned for Baldock can be accommodated in highways terms.
6. Nor does it appear that the financial viability of the proposed mitigation measures has been tested fully, especially if a new crossing of the railway is to be delivered without unacceptable visual impacts, and without prohibitive costs being imposed by Network Rail. The Local Plan Viability Assessment (Update, August 2016) has only taken an indicative approach to assessing the potential viability of the major sites, rather than looking at the specific infrastructure pressures and mitigation measures associated with each.

Third, the plan is not consistent with national policy. While the National Planning Policy Framework is clear that the evidence base for plans should be proportionate, it is equally clear that plans should identify whether transport improvements can be made to limit the significant impacts of development, and that where the residual cumulative impacts are severe there may be a case for preventing development (para. 32).

The Proposed Submission Local Plan does not satisfy this test. As set out above, it's very clear that the full impact of the scale of development proposed for Baldock, or of individual major site proposals, has not been properly assessed, with no information available on the impact and viability of the proposed mitigation measures.

This applies not only to site BA1, but also to the other major sites: for example, the plan mentions a new "southern link road" in relation to sites BA3 and BA4, but no further information to explain its route, viability or impact is provided in the plan or supporting documents.

The Odyssey Markides technical note for the Council asserts (para. 1.5) that "there are no issues that have emerged from the transport modelling work that... would cause a significant highway issue that cannot be resolved through appropriate mitigation measures". This conclusion is fundamentally flawed, resting as it does only on the wholly inadequate transport modelling work that has been undertaken.

The scale of employment growth proposed for this site is excessive, given the size of Baldock and the cumulative impact that trips from the development are likely to have on the local highways network, alongside those from the proposed residential sites (see representations on Baldock as a whole).