Local Plan 2011-2031 Proposed Submission Draft

PLEASE ACKNOWLEDGE RECEIPT OF THIS EMAIL

I am writing to submit my objection as a resident of the Parish of Bygrave to the Draft Local Plan, and the designation of Green Belt land to be allocated as housing sites within the Parish of Bygrave, to the north of Baldock.

I submit this objection on the basis that I do not think that the Local Plan has been objectively prepared, is justified, or effective and consistent with national policy.

It is appropriate that you should know that I am not a 'NIMBY', and fully understand and support the need for the country to have plans for future housing requirements. However the 'Updating the Overall Housing Needs' by ORS in 08/2016 document, states at;

para. 2 - that the 'projected increase in households across Stevenage and North Hertfordshire... based on rates from the 2012-based data and migration trends established using Mid-year Estimated data from the period 2005-15.

para. 6 - ..household projections are based on the ONS 2014-based SNPP, which are informed by migration trends from the 5-year period 2009-14. Future projections are particularly sensitive to the period on which migration trends are based, and PAS advise to Local Authorities suggests that the official projections are "VERY UNSTABLE". ...This viewed is echoed by academics and has been promoted by Planning Inspectors at numerous Local Planning Examinations.

Based on the above, I believe there should be greater 'push back' by NHDC in their Local Plan until numbers can be produced with greater clarity and certainty. Of greater importance is the fact that the EU Referendum has not been factored in to any of these projections, a situation which in the period up to 2031, could have dramatic implications both to the immigration numbers, to the number of EU citizens who currently live in the UK but who potentially could be forced to return to their home country, and to the economic situation of the UK (with its attendant housing implications). To use some of the wording of the North Hertfordshire Proposed Submission Local Planning Sustainability Appraisal Report under the heading of Nature of Effect, 'the loss of agricultural land is cumulative across the Plan area, of high probability, permanent and irreversible'. This Plan needs to be compiled on the basis of facts, which can be substantiated, not a wish list, based on guesstimates.

Turning to the North Hertfordshire Green Belt Review - July 2016, Table 2.2 'Green Belt Assessment Criteria' states that it is, "To preserve the setting and special character of historic towns" (Baldock is known as a 'Historic Market Town') Referring to the parcel of land marked 21 "Bygrave", it states that it "makes a Significant Contribution to restricting sprawl" and "Prevents urbanising influences". Figure 2.4 - "Contribution to checking the unrestricted sprawl of large built up areas", and Figure 2.6 "Contribution to Safeguarding the Countryside from Encroachment" both show parcel 21 "Bygrave" as making a SIGNIFICANT CONTRIBUTION.

Para. 49 states "The areas which contribute most to the purposes of the Green Belt are those around the periphery of, and between, the existing settlements of Hitchin, Letchworth and Baldock ... An additional factor in the assessment is the historic nature of the three Hertfordshire towns located within the Green Belt and their proximity to one another, resulting in increased sensitivity to development".

Page 125, "Green Belt Review Site Assessment - Baldock and East Letchworth" states that the whole site, designated this time as 200 representing the area north of Baldock, is shown as providing a SIGNIFICANT CONTRIBUTION TO GREEN BELT".

Page 134, Conversely at another site designated "West of Stevenage", this provides only a Moderate Contribution.

Para. 87, includes the statement "Stevenage Borough Council has removed an area from the Green Belt to the West of the A1(M)".

Para 93, states that "... consideration has been given to the need to identify safeguarded land for meeting development needs in the longer term. This function is met by the removal of the west Stevenage strategic site and employment land at Baldock from the Green Belt".

In this Green Belt Review, the Baldock sites have been identified as making a significant contribution to achieving the aim of a Green Belt. However the statement in para. 93 simply says that land at Baldock has been removed from that Green Belt. I can find no objective approach or basis for this action. Given that other sites have been identified as generating a lesser contribution to the Green Belt aims in this document, NHDC should be required to demonstrate why these sites have not taken precedent over the Baldock sites which make a greater contribution, since the approach they have taken is neither effective nor consistent with national policy.

The following now make reference to the National Planning Policy Framework (NPPF) 03/2012.

A part of the Ministerial prologue requires that "Sustainable development is about change for the better. ... This should be a collective enterprise. Yet in recent years, planning has tended to exclude, rather than include, people and communities. In part, this has been a result of targets being imposed, and decisions taken, by bodies remote from them. Dismantling this unaccountable region apparatus, and introducing neighbourhood planning, addresses this".

Para. 9 provides that "Pursuing sustainable development involves seeking positive improvements in ... the conditions in which people live, work, travel, and take leisure".

Para. 17 addresses "Core planning principles - a set of core land-use planning principles should underpin both plan-making and decision taking. The 12 principles include;
Bullet 1 - "be genuinely plan-lead, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area";
Bullet 5 - "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belt around them, recognising the intrinsic character and beauty of the countryside and supporting thriving communities within it";
Bullet 7 - "contribute to conserving and enhancing the natural environment and reducing pollution"; and
Bullet 11 - "actively manage patterns of growth and make the fullest possible use of public transport".

Para 28 requires "Supporting a prosperous rural economy. - Planning policies should support economic growth in rural areas, and should (bullet 2) promote the development and diversification of agricultural and other land-based rural businesses".

So taking the requirements of the NPPF, we need to have change for the better, not just change. The people of Baldock and Bygrave should be included and have notice taken of their views and wishes to shape the town and surrounding area, not to have been excluded, which is how I see the process of communication by NHDC at meetings has taken shape, with a tone of 'go away you little people, I have things to do my way'. Once again reference is made of the need to protecting the Green Belt, and also to promote agriculture, the activity currently undertaken on the land north of Baldock. Far too little attention has been paid to travel requirements, to determine whether the existing arrangements could cope with approx. 2,800 houses north of Baldock. Currently the Bygrave Road is totally unsuitable to take more traffic, there is no plan shown (and if there is one, why has it not been declared to the public) for a bridge or underpass over / under the railway to the south, which leaves any traffic wishing to go south into Baldock having to go under the railway bridge on the Great North Road, almost under the railway station. That section of road already suffers considerable and lengthy delays, and realistically, should not be considered an option should the north of Baldock site go ahead.

In summary, it feels as if the fact that Hertfordshire County Council own the land at the north of Baldock site, makes it an easy option for NHDC to choose this site as their Local Plan for 2015-31, and as a result they have not put together an object argument to justify this location, as opposed to others in the area, but which would not give them such an easy option. As stated above, once land has been built on, there is no going back. Greater consideration also needs to be given to the actual number of houses NEEDED, and if this means deferring a decision until substantive data is available, then that should be the appropriate action to take. Greater consideration should also be given to transport - one might assume a fair number of the people would need to commute by train. Rather than the plan saying that the platform at Baldock will be extended to take the extra commuters, the latest plan, recently released by the railway operator, shows that they actually plan to CUT the number of trains stopping at Baldock station. Likewise, how will people be able to drive into Baldock given that the existing road is already suffering major delays.

Finally I again submit that I am not a NIMBY, but it certainly is not equitable that a small historic market town, which is on the edge of a Green Belt, should be burdened with totally disproportionate to the size of the town, the largest number of houses for the NHDC Local Plan.

The plan should not be accepted in its present form, but overhauled to make it objective and proportionate across all towns in the area.

I shall be grateful if you will keep me informed of all developments in the matter.

PLEASE ACKNOWLEDGE RECEIPT OF THIS EMAIL

I am writing to submit my objection as a resident of the Parish of Bygrave to the Draft Local Plan, and the designation of Green Belt land to be allocated as housing sites within the Parish of Bygrave, to the north of Baldock.

I submit this objection on the basis that I do not think that the Local Plan has been objectively prepared, is justified, or effective and consistent with national policy.

It is appropriate that you should know that I am not a 'NIMBY', and fully understand and support the need for the country to have plans for future housing requirements. However the 'Updating the Overall Housing Needs' by ORS in 08/2016 document, states at;

para. 2 - that the 'projected increase in households across Stevenage and North Hertfordshire... based on rates from the 2012-based data and migration trends established using Mid-year Estimated data from the period 2005-15.

para. 6 - ..household projections are based on the ONS 2014-based SNPP, which are informed by migration trends from the 5-year period 2009-14. Future projections are particularly sensitive to the period on which migration trends are based, and PAS advise to Local Authorities suggests that the official projections are "VERY UNSTABLE". ...This viewed is echoed by academics and has been promoted by Planning Inspectors at numerous Local Planning Examinations.

Based on the above, I believe there should be greater 'push back' by NHDC in their Local Plan until numbers can be produced with greater clarity and certainty. Of greater importance is the fact that the EU Referendum has not been factored in to any of these projections, a situation which in the period up to 2031, could have dramatic implications both to the immigration numbers, to the number of EU citizens who currently live in the UK but who potentially could be forced to return to their home country, and to the economic situation of the UK (with its attendant housing implications). To use some of the wording of the North Hertfordshire Proposed Submission Local Planning Sustainability Appraisal Report under the heading of Nature of Effect, 'the loss of agricultural land is cumulative across the Plan area, of high probability, permanent and irreversible'. This Plan needs to be compiled on the basis of facts, which can be substantiated, not a wish list, based on guesstimates.

Turning to the North Hertfordshire Green Belt Review - July 2016, Table 2.2 'Green Belt Assessment Criteria' states that it is, "To preserve the setting and special character of historic towns" (Baldock is known as a 'Historic Market Town') Referring to the parcel of land marked 21 "Bygrave", it states that it "makes a Significant Contribution to restricting sprawl" and "Prevents urbanising influences". Figure 2.4 - "Contribution to checking the unrestricted sprawl of large built up areas", and Figure 2.6 "Contribution to Safeguarding the Countryside from Encroachment" both show parcel 21 "Bygrave" as making a SIGNIFICANT CONTRIBUTION.

Para. 49 states "The areas which contribute most to the purposes of the Green Belt are those around the periphery of, and between, the existing settlements of Hitchin, Letchworth and Baldock ... An additional factor in the assessment is the historic nature of the three Hertfordshire towns located within the Green Belt and their proximity to one another, resulting in increased sensitivity to development".

Page 125, "Green Belt Review Site Assessment - Baldock and East Letchworth" states that the whole site, designated this time as 200 representing the area north of Baldock, is shown as providing a SIGNIFICANT CONTRIBUTION TO GREEN BELT".

Page 134, Conversely at another site designated "West of Stevenage", this provides only a Moderate Contribution.

Para. 87, includes the statement "Stevenage Borough Council has removed an area from the Green Belt to the West of the A1(M)".

Para 93, states that "... consideration has been given to the need to identify safeguarded land for meeting development needs in the longer term. This function is met by the removal of the west Stevenage strategic site and employment land at Baldock from the Green Belt".

In this Green Belt Review, the Baldock sites have been identified as making a significant contribution to achieving the aim of a Green Belt. However the statement in para. 93 simply says that land at Baldock has been removed from that Green Belt. I can find no objective approach or basis for this action. Given that other sites have been identified as generating a lesser contribution to the Green Belt aims in this document, NHDC should be required to demonstrate why these sites have not taken precedent over the Baldock sites which make a greater contribution, since the approach they have taken is neither effective nor consistent with national policy.

The following now make reference to the National Planning Policy Framework (NPPF) 03/2012.

A part of the Ministerial prologue requires that "Sustainable development is about change for the better. ... This should be a collective enterprise. Yet in recent years, planning has tended to exclude, rather than include, people and communities. In part, this has been a result of targets being imposed, and decisions taken, by bodies remote from them. Dismantling this unaccountable region apparatus, and introducing neighbourhood planning, addresses this".

Para. 9 provides that "Pursuing sustainable development involves seeking positive improvements in ... the conditions in which people live, work, travel, and take leisure".

Para. 17 addresses "Core planning principles - a set of core land-use planning principles should underpin both plan-making and decision taking. The 12 principles include;
Bullet 1 - "be genuinely plan-lead, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area";
Bullet 5 - "take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belt around them, recognising the intrinsic character and beauty of the countryside and supporting thriving communities within it";
Bullet 7 - "contribute to conserving and enhancing the natural environment and reducing pollution"; and
Bullet 11 - "actively manage patterns of growth and make the fullest possible use of public transport".

Para 28 requires "Supporting a prosperous rural economy. - Planning policies should support economic growth in rural areas, and should (bullet 2) promote the development and diversification of agricultural and other land-based rural businesses".

So taking the requirements of the NPPF, we need to have change for the better, not just change. The people of Baldock and Bygrave should be included and have notice taken of their views and wishes to shape the town and surrounding area, not to have been excluded, which is how I see the process of communication by NHDC at meetings has taken shape, with a tone of 'go away you little people, I have things to do my way'. Once again reference is made of the need to protecting the Green Belt, and also to promote agriculture, the activity currently undertaken on the land north of Baldock. Far too little attention has been paid to travel requirements, to determine whether the existing arrangements could cope with approx. 2,800 houses north of Baldock. Currently the Bygrave Road is totally unsuitable to take more traffic, there is no plan shown (and if there is one, why has it not been declared to the public) for a bridge or underpass over / under the railway to the south, which leaves any traffic wishing to go south into Baldock having to go under the railway bridge on the Great North Road, almost under the railway station. That section of road already suffers considerable and lengthy delays, and realistically, should not be considered an option should the north of Baldock site go ahead.

In summary, it feels as if the fact that Hertfordshire County Council own the land at the north of Baldock site, makes it an easy option for NHDC to choose this site as their Local Plan for 2015-31, and as a result they have not put together an object argument to justify this location, as opposed to others in the area, but which would not give them such an easy option. As stated above, once land has been built on, there is no going back. Greater consideration also needs to be given to the actual number of houses NEEDED, and if this means deferring a decision until substantive data is available, then that should be the appropriate action to take. Greater consideration should also be given to transport - one might assume a fair number of the people would need to commute by train. Rather than the plan saying that the platform at Baldock will be extended to take the extra commuters, the latest plan, recently released by the railway operator, shows that they actually plan to CUT the number of trains stopping at Baldock station. Likewise, how will people be able to drive into Baldock given that the existing road is already suffering major delays.

Finally I again submit that I am not a NIMBY, but it certainly is not equitable that a small historic market town, which is on the edge of a Green Belt, should be burdened with totally disproportionate to the size of the town, the largest number of houses for the NHDC Local Plan.

The plan should not be accepted in its present form, but overhauled to make it objective and proportionate across all towns in the area.

I shall be grateful if you will keep me informed of all developments in the matter.