Baldock, Bygrave & Clothall Neighbourhood Plan - Submission Version

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Comment

Baldock, Bygrave & Clothall Neighbourhood Plan - Submission Version

Introduction

Representation ID: 8397

Received: 24/03/2020

Respondent: Hertfordshire County Council - Environment & Infrastructure Department

Representation:

See full representation

Full text:

HCC Welcomes the opportunity to provide comment on the Regulation 16 Baldock, Bygrave and Clothall Neighbourhood Plan.

There are some rather significant allocated sites set in the forthcoming North Herts Local Plan which will have an undoubtedly significant impact on the local area. The adoption of this Neighbourhood Plan would see it become part of the development plan for this area of North Hertfordshire. HCC therefore welcomes the policies in this neighbourhood plan which build on those policies in the North Herts Local Plan, adding local context and a community minded approach to planning to ensure the best possible development for the area.

Given the environmental challenges that we face going forward and the declaration of a Climate Emergency, HCC welcomes the efforts made in the neighbourhood Plan to ensure sustainable development and design methods are used as reflected in Policy G4.

HCC Services have made the following observations and comments on the Neighbourhood Plan;

Historic Environment

We welcome this Neighbourhood Plan’s inclusion of the historic environment within its policies G5 and G6. G6 provides for local (built) heritage assets, with G5 concerned with conservation areas, and we are supportive of both.
We are concerned however, that there is no direct mention of undesignated or designated assets of archaeological interest within either policy – both dealing almost exclusively with above ground, built heritage, assets. As the Neighbourhood Plan mentions elsewhere, the area covered by this plan contains some of the most significant archaeological remains in Hertfordshire, some of which are nationally significant. As well as those areas that we know of (e.g. the Late Iron Age/Roman settlements at Walls Field and Blackhorse Farm), cropmark evidence suggests that there are widespread significant archaeological remains, perhaps also of national significance, that lie undisturbed below ground, particularly within currently agricultural areas, and within the town of Baldock itself. It should be noted that around 1800 human burials from the Late Iron Age/Roman period have been excavated within Baldock since 1925, while a minimum of 21 formal cemeteries have been identified.
Should a development have potential to impact on any potential significant archaeological remains an appropriate archaeological investigation should take place, as per NPPF para 189: “Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.” Should remains of significance be identified appropriate steps should be taken to mitigate the impact of development on the identified asset.

We would therefore strongly recommend that the wording of policy G6 be amended to provide for known and as yet unknown below ground archaeological remains within the three parishes.

Minerals and Waste

Waste
Of particular concern to the county council, as the Waste Planning Authority, is the management of construction, demolition and excavation waste. This waste stream presents the biggest capacity gap for Hertfordshire, meaning that there are significant volumes of this waste that cannot be treated in the county. Therefore, every effort should be made in the construction of new developments, to minimise waste generated throughout all phases (i.e. demolition, construction and subsequent occupation).
The Submission Neighbourhood Plan identifies the substantial level of growth being planned for that falls within the plan area (as set out in the emerging North Herts Local Plan). There are particularly high levels of growth being planned for in and around the Baldock area, as Figure 2 of the Neighbourhood Plan shows.

Policy E3 (Policy E3: Managing Construction Impacts) of the Neighbourhood Plan requires that the developments which come forward on site allocations BA1, BA2, BA3, BA4 and BA10 (i.e. the housing allocations in Baldock) limit off-site construction waste disposal.

From the Waste Planning Authority’s perspective, it is very encouraging to see that the Parish Council have included this criterion in Policy E3 and are seeking help in the initiative to reduce construction waste and subsequently help manage the high volumes of waste that are likely to arise as a result of the developments in the Baldock area.

The Neighbourhood Plan also addresses importance of new buildings being constructed in more sustainable ways.

Page 33 of The Design Guidelines (appended to the Neighbourhood Plan), sets out the fact that modern requirements for waste separation and recycling require the need for more bin storage and that it is important that adequate bin storage be incorporated into developments.

With the high levels of growth in mind (at site allocations BA1, BA2, BA3, BA4 and BA10), the Waste Planning Authority is pleased to see that the Guidelines will encourage waste segregation at its source and require developments to be designed in a way which will accommodate to a higher level of waste storage.

The county council, as the Minerals and Waste Planning Authority, would like to conclude by taking the opportunity to reiterate the comments it made in response to the Plan Area Designation Consultation in June 2017.
The Parish Council should note that the plan area contains Employment Land Area of Search (ELAS) 201 and is also located adjacent to ELAS 026. ELAS are based upon employment areas designated by District and Borough Council’s (within their Local Plans) and are considered potentially compatible with waste management uses (because they contain B2 and/or B8 uses).
There is potential for waste management facilities to come forward within these areas throughout the remainder of the life of the adopted Waste Local Plan (i.e. until they are no longer part of adopted Policy and the emerging Waste Local Plan is adopted- which is anticipated for 2021/2022).
It is also worth noting that Cumberlow Green Farm Composting Facility is situated just outside of the Neighbourhood Plan area (located to the south east of Munches Wood, along the A507). This facility is safeguarded under Policy 5 of the adopted Waste Local Plan and is also one of eight Allocated Sites identified in the adopted Waste Local Plan.

Highways

As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire whilst minimising impact on the environment. Hertfordshire County Council adopted Local Transport Plan 4 (LTP4) 2018 – 2031 which sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 will provide a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

Vision and Objectives
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority however the following comments are provided on the policies within the plan
Policies within the Neighbourhood Plan need to support LTP4 Policy 1: Transport User Hierarchy which states “to support the creation of built environments that encourage greater and safer use of sustainable transport modes, the county council will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs


Policy specific Comments
Policy G1: Improving access and parking
A parking assessment needs to be undertaken to establish an understanding and the correct balance required for additional parking to serve Baldock railway station. Any proposals for additional car parking at the railway station would have to be considered carefully as such measures can lead to increased car journeys.
Include within the policy that complementary (non-planning) measures may need to be considered such as further parking restrictions (e.g. CPZ) which is currently part of the supporting text for reason for this policy.
C) Changes to the drop-off and pick up arrangements serving Knights Templar this is unclear what you are trying to achieve and why. To support LTP4 the focus needs be on bus drop-off and not to support private vehicles.

Policy E1: Transport and air quality
This policy highlights that strategic sites in the North Hertfordshire Local Plan should not be permitted if the Whitehorse Street/Station Road crossroads junction is operating above capacity which might constitute as being severe. This however needs to be approached with a balanced view, one junction on its own is unlikely to result is a ‘severe’ impact. The Highway Authority would recommend greater alignment with NPPF which states “All developments which generate significant amounts of movement should be required to provide a Travel Plan”

Other comments
The Neighbourhood Plan does not include bus priority measures which can encourage people to travel by different modes of sustainable transport rather than private cars. It is an efficient traffic management solution which can reduce congestion/pollution in areas.
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority
Hertfordshire County Council Highways would welcome the opportunity to continue working together to develop a plan that contributes to the overall vision for Hertfordshire.

Comment

Baldock, Bygrave & Clothall Neighbourhood Plan - Submission Version

Policy G4 - Sustainable design

Representation ID: 8408

Received: 24/03/2020

Respondent: Hertfordshire County Council - Environment & Infrastructure Department

Representation:

Given the environmental challenges that we face going forward and the declaration of a Climate Emergency, HCC welcomes the efforts made in the neighbourhood Plan to ensure sustainable development and design methods are used as reflected in Policy G4.

Full text:

HCC Welcomes the opportunity to provide comment on the Regulation 16 Baldock, Bygrave and Clothall Neighbourhood Plan.

There are some rather significant allocated sites set in the forthcoming North Herts Local Plan which will have an undoubtedly significant impact on the local area. The adoption of this Neighbourhood Plan would see it become part of the development plan for this area of North Hertfordshire. HCC therefore welcomes the policies in this neighbourhood plan which build on those policies in the North Herts Local Plan, adding local context and a community minded approach to planning to ensure the best possible development for the area.

Given the environmental challenges that we face going forward and the declaration of a Climate Emergency, HCC welcomes the efforts made in the neighbourhood Plan to ensure sustainable development and design methods are used as reflected in Policy G4.

HCC Services have made the following observations and comments on the Neighbourhood Plan;

Historic Environment

We welcome this Neighbourhood Plan’s inclusion of the historic environment within its policies G5 and G6. G6 provides for local (built) heritage assets, with G5 concerned with conservation areas, and we are supportive of both.
We are concerned however, that there is no direct mention of undesignated or designated assets of archaeological interest within either policy – both dealing almost exclusively with above ground, built heritage, assets. As the Neighbourhood Plan mentions elsewhere, the area covered by this plan contains some of the most significant archaeological remains in Hertfordshire, some of which are nationally significant. As well as those areas that we know of (e.g. the Late Iron Age/Roman settlements at Walls Field and Blackhorse Farm), cropmark evidence suggests that there are widespread significant archaeological remains, perhaps also of national significance, that lie undisturbed below ground, particularly within currently agricultural areas, and within the town of Baldock itself. It should be noted that around 1800 human burials from the Late Iron Age/Roman period have been excavated within Baldock since 1925, while a minimum of 21 formal cemeteries have been identified.
Should a development have potential to impact on any potential significant archaeological remains an appropriate archaeological investigation should take place, as per NPPF para 189: “Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.” Should remains of significance be identified appropriate steps should be taken to mitigate the impact of development on the identified asset.

We would therefore strongly recommend that the wording of policy G6 be amended to provide for known and as yet unknown below ground archaeological remains within the three parishes.

Minerals and Waste

Waste
Of particular concern to the county council, as the Waste Planning Authority, is the management of construction, demolition and excavation waste. This waste stream presents the biggest capacity gap for Hertfordshire, meaning that there are significant volumes of this waste that cannot be treated in the county. Therefore, every effort should be made in the construction of new developments, to minimise waste generated throughout all phases (i.e. demolition, construction and subsequent occupation).
The Submission Neighbourhood Plan identifies the substantial level of growth being planned for that falls within the plan area (as set out in the emerging North Herts Local Plan). There are particularly high levels of growth being planned for in and around the Baldock area, as Figure 2 of the Neighbourhood Plan shows.

Policy E3 (Policy E3: Managing Construction Impacts) of the Neighbourhood Plan requires that the developments which come forward on site allocations BA1, BA2, BA3, BA4 and BA10 (i.e. the housing allocations in Baldock) limit off-site construction waste disposal.

From the Waste Planning Authority’s perspective, it is very encouraging to see that the Parish Council have included this criterion in Policy E3 and are seeking help in the initiative to reduce construction waste and subsequently help manage the high volumes of waste that are likely to arise as a result of the developments in the Baldock area.

The Neighbourhood Plan also addresses importance of new buildings being constructed in more sustainable ways.

Page 33 of The Design Guidelines (appended to the Neighbourhood Plan), sets out the fact that modern requirements for waste separation and recycling require the need for more bin storage and that it is important that adequate bin storage be incorporated into developments.

With the high levels of growth in mind (at site allocations BA1, BA2, BA3, BA4 and BA10), the Waste Planning Authority is pleased to see that the Guidelines will encourage waste segregation at its source and require developments to be designed in a way which will accommodate to a higher level of waste storage.

The county council, as the Minerals and Waste Planning Authority, would like to conclude by taking the opportunity to reiterate the comments it made in response to the Plan Area Designation Consultation in June 2017.
The Parish Council should note that the plan area contains Employment Land Area of Search (ELAS) 201 and is also located adjacent to ELAS 026. ELAS are based upon employment areas designated by District and Borough Council’s (within their Local Plans) and are considered potentially compatible with waste management uses (because they contain B2 and/or B8 uses).
There is potential for waste management facilities to come forward within these areas throughout the remainder of the life of the adopted Waste Local Plan (i.e. until they are no longer part of adopted Policy and the emerging Waste Local Plan is adopted- which is anticipated for 2021/2022).
It is also worth noting that Cumberlow Green Farm Composting Facility is situated just outside of the Neighbourhood Plan area (located to the south east of Munches Wood, along the A507). This facility is safeguarded under Policy 5 of the adopted Waste Local Plan and is also one of eight Allocated Sites identified in the adopted Waste Local Plan.

Highways

As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire whilst minimising impact on the environment. Hertfordshire County Council adopted Local Transport Plan 4 (LTP4) 2018 – 2031 which sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 will provide a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

Vision and Objectives
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority however the following comments are provided on the policies within the plan
Policies within the Neighbourhood Plan need to support LTP4 Policy 1: Transport User Hierarchy which states “to support the creation of built environments that encourage greater and safer use of sustainable transport modes, the county council will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs


Policy specific Comments
Policy G1: Improving access and parking
A parking assessment needs to be undertaken to establish an understanding and the correct balance required for additional parking to serve Baldock railway station. Any proposals for additional car parking at the railway station would have to be considered carefully as such measures can lead to increased car journeys.
Include within the policy that complementary (non-planning) measures may need to be considered such as further parking restrictions (e.g. CPZ) which is currently part of the supporting text for reason for this policy.
C) Changes to the drop-off and pick up arrangements serving Knights Templar this is unclear what you are trying to achieve and why. To support LTP4 the focus needs be on bus drop-off and not to support private vehicles.

Policy E1: Transport and air quality
This policy highlights that strategic sites in the North Hertfordshire Local Plan should not be permitted if the Whitehorse Street/Station Road crossroads junction is operating above capacity which might constitute as being severe. This however needs to be approached with a balanced view, one junction on its own is unlikely to result is a ‘severe’ impact. The Highway Authority would recommend greater alignment with NPPF which states “All developments which generate significant amounts of movement should be required to provide a Travel Plan”

Other comments
The Neighbourhood Plan does not include bus priority measures which can encourage people to travel by different modes of sustainable transport rather than private cars. It is an efficient traffic management solution which can reduce congestion/pollution in areas.
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority
Hertfordshire County Council Highways would welcome the opportunity to continue working together to develop a plan that contributes to the overall vision for Hertfordshire.

Comment

Baldock, Bygrave & Clothall Neighbourhood Plan - Submission Version

Policy G5 - Baldock conservation area

Representation ID: 8409

Received: 24/03/2020

Respondent: Hertfordshire County Council - Environment & Infrastructure Department

Representation:

Welcome the Neighbourhood Plan’s inclusion of the historic environment within its policies G5 and G6. Concerned that there is no direct mention of undesignated or designated assets of archaeological interest in either Policy G5 or Policy G6.

See full representation.

Full text:

HCC Welcomes the opportunity to provide comment on the Regulation 16 Baldock, Bygrave and Clothall Neighbourhood Plan.

There are some rather significant allocated sites set in the forthcoming North Herts Local Plan which will have an undoubtedly significant impact on the local area. The adoption of this Neighbourhood Plan would see it become part of the development plan for this area of North Hertfordshire. HCC therefore welcomes the policies in this neighbourhood plan which build on those policies in the North Herts Local Plan, adding local context and a community minded approach to planning to ensure the best possible development for the area.

Given the environmental challenges that we face going forward and the declaration of a Climate Emergency, HCC welcomes the efforts made in the neighbourhood Plan to ensure sustainable development and design methods are used as reflected in Policy G4.

HCC Services have made the following observations and comments on the Neighbourhood Plan;

Historic Environment

We welcome this Neighbourhood Plan’s inclusion of the historic environment within its policies G5 and G6. G6 provides for local (built) heritage assets, with G5 concerned with conservation areas, and we are supportive of both.
We are concerned however, that there is no direct mention of undesignated or designated assets of archaeological interest within either policy – both dealing almost exclusively with above ground, built heritage, assets. As the Neighbourhood Plan mentions elsewhere, the area covered by this plan contains some of the most significant archaeological remains in Hertfordshire, some of which are nationally significant. As well as those areas that we know of (e.g. the Late Iron Age/Roman settlements at Walls Field and Blackhorse Farm), cropmark evidence suggests that there are widespread significant archaeological remains, perhaps also of national significance, that lie undisturbed below ground, particularly within currently agricultural areas, and within the town of Baldock itself. It should be noted that around 1800 human burials from the Late Iron Age/Roman period have been excavated within Baldock since 1925, while a minimum of 21 formal cemeteries have been identified.
Should a development have potential to impact on any potential significant archaeological remains an appropriate archaeological investigation should take place, as per NPPF para 189: “Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.” Should remains of significance be identified appropriate steps should be taken to mitigate the impact of development on the identified asset.

We would therefore strongly recommend that the wording of policy G6 be amended to provide for known and as yet unknown below ground archaeological remains within the three parishes.

Minerals and Waste

Waste
Of particular concern to the county council, as the Waste Planning Authority, is the management of construction, demolition and excavation waste. This waste stream presents the biggest capacity gap for Hertfordshire, meaning that there are significant volumes of this waste that cannot be treated in the county. Therefore, every effort should be made in the construction of new developments, to minimise waste generated throughout all phases (i.e. demolition, construction and subsequent occupation).
The Submission Neighbourhood Plan identifies the substantial level of growth being planned for that falls within the plan area (as set out in the emerging North Herts Local Plan). There are particularly high levels of growth being planned for in and around the Baldock area, as Figure 2 of the Neighbourhood Plan shows.

Policy E3 (Policy E3: Managing Construction Impacts) of the Neighbourhood Plan requires that the developments which come forward on site allocations BA1, BA2, BA3, BA4 and BA10 (i.e. the housing allocations in Baldock) limit off-site construction waste disposal.

From the Waste Planning Authority’s perspective, it is very encouraging to see that the Parish Council have included this criterion in Policy E3 and are seeking help in the initiative to reduce construction waste and subsequently help manage the high volumes of waste that are likely to arise as a result of the developments in the Baldock area.

The Neighbourhood Plan also addresses importance of new buildings being constructed in more sustainable ways.

Page 33 of The Design Guidelines (appended to the Neighbourhood Plan), sets out the fact that modern requirements for waste separation and recycling require the need for more bin storage and that it is important that adequate bin storage be incorporated into developments.

With the high levels of growth in mind (at site allocations BA1, BA2, BA3, BA4 and BA10), the Waste Planning Authority is pleased to see that the Guidelines will encourage waste segregation at its source and require developments to be designed in a way which will accommodate to a higher level of waste storage.

The county council, as the Minerals and Waste Planning Authority, would like to conclude by taking the opportunity to reiterate the comments it made in response to the Plan Area Designation Consultation in June 2017.
The Parish Council should note that the plan area contains Employment Land Area of Search (ELAS) 201 and is also located adjacent to ELAS 026. ELAS are based upon employment areas designated by District and Borough Council’s (within their Local Plans) and are considered potentially compatible with waste management uses (because they contain B2 and/or B8 uses).
There is potential for waste management facilities to come forward within these areas throughout the remainder of the life of the adopted Waste Local Plan (i.e. until they are no longer part of adopted Policy and the emerging Waste Local Plan is adopted- which is anticipated for 2021/2022).
It is also worth noting that Cumberlow Green Farm Composting Facility is situated just outside of the Neighbourhood Plan area (located to the south east of Munches Wood, along the A507). This facility is safeguarded under Policy 5 of the adopted Waste Local Plan and is also one of eight Allocated Sites identified in the adopted Waste Local Plan.

Highways

As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire whilst minimising impact on the environment. Hertfordshire County Council adopted Local Transport Plan 4 (LTP4) 2018 – 2031 which sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 will provide a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

Vision and Objectives
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority however the following comments are provided on the policies within the plan
Policies within the Neighbourhood Plan need to support LTP4 Policy 1: Transport User Hierarchy which states “to support the creation of built environments that encourage greater and safer use of sustainable transport modes, the county council will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs


Policy specific Comments
Policy G1: Improving access and parking
A parking assessment needs to be undertaken to establish an understanding and the correct balance required for additional parking to serve Baldock railway station. Any proposals for additional car parking at the railway station would have to be considered carefully as such measures can lead to increased car journeys.
Include within the policy that complementary (non-planning) measures may need to be considered such as further parking restrictions (e.g. CPZ) which is currently part of the supporting text for reason for this policy.
C) Changes to the drop-off and pick up arrangements serving Knights Templar this is unclear what you are trying to achieve and why. To support LTP4 the focus needs be on bus drop-off and not to support private vehicles.

Policy E1: Transport and air quality
This policy highlights that strategic sites in the North Hertfordshire Local Plan should not be permitted if the Whitehorse Street/Station Road crossroads junction is operating above capacity which might constitute as being severe. This however needs to be approached with a balanced view, one junction on its own is unlikely to result is a ‘severe’ impact. The Highway Authority would recommend greater alignment with NPPF which states “All developments which generate significant amounts of movement should be required to provide a Travel Plan”

Other comments
The Neighbourhood Plan does not include bus priority measures which can encourage people to travel by different modes of sustainable transport rather than private cars. It is an efficient traffic management solution which can reduce congestion/pollution in areas.
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority
Hertfordshire County Council Highways would welcome the opportunity to continue working together to develop a plan that contributes to the overall vision for Hertfordshire.

Comment

Baldock, Bygrave & Clothall Neighbourhood Plan - Submission Version

Policy G6 - Local Heritage assets

Representation ID: 8410

Received: 24/03/2020

Respondent: Hertfordshire County Council - Environment & Infrastructure Department

Representation:

Welcome the Neighbourhood Plan’s inclusion of the historic environment within its policies G5 and G6. Concerned that there is no direct mention of undesignated or designated assets of archaeological interest in either Policy G5 or Policy G6.

See full representation.

Full text:

HCC Welcomes the opportunity to provide comment on the Regulation 16 Baldock, Bygrave and Clothall Neighbourhood Plan.

There are some rather significant allocated sites set in the forthcoming North Herts Local Plan which will have an undoubtedly significant impact on the local area. The adoption of this Neighbourhood Plan would see it become part of the development plan for this area of North Hertfordshire. HCC therefore welcomes the policies in this neighbourhood plan which build on those policies in the North Herts Local Plan, adding local context and a community minded approach to planning to ensure the best possible development for the area.

Given the environmental challenges that we face going forward and the declaration of a Climate Emergency, HCC welcomes the efforts made in the neighbourhood Plan to ensure sustainable development and design methods are used as reflected in Policy G4.

HCC Services have made the following observations and comments on the Neighbourhood Plan;

Historic Environment

We welcome this Neighbourhood Plan’s inclusion of the historic environment within its policies G5 and G6. G6 provides for local (built) heritage assets, with G5 concerned with conservation areas, and we are supportive of both.
We are concerned however, that there is no direct mention of undesignated or designated assets of archaeological interest within either policy – both dealing almost exclusively with above ground, built heritage, assets. As the Neighbourhood Plan mentions elsewhere, the area covered by this plan contains some of the most significant archaeological remains in Hertfordshire, some of which are nationally significant. As well as those areas that we know of (e.g. the Late Iron Age/Roman settlements at Walls Field and Blackhorse Farm), cropmark evidence suggests that there are widespread significant archaeological remains, perhaps also of national significance, that lie undisturbed below ground, particularly within currently agricultural areas, and within the town of Baldock itself. It should be noted that around 1800 human burials from the Late Iron Age/Roman period have been excavated within Baldock since 1925, while a minimum of 21 formal cemeteries have been identified.
Should a development have potential to impact on any potential significant archaeological remains an appropriate archaeological investigation should take place, as per NPPF para 189: “Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.” Should remains of significance be identified appropriate steps should be taken to mitigate the impact of development on the identified asset.

We would therefore strongly recommend that the wording of policy G6 be amended to provide for known and as yet unknown below ground archaeological remains within the three parishes.

Minerals and Waste

Waste
Of particular concern to the county council, as the Waste Planning Authority, is the management of construction, demolition and excavation waste. This waste stream presents the biggest capacity gap for Hertfordshire, meaning that there are significant volumes of this waste that cannot be treated in the county. Therefore, every effort should be made in the construction of new developments, to minimise waste generated throughout all phases (i.e. demolition, construction and subsequent occupation).
The Submission Neighbourhood Plan identifies the substantial level of growth being planned for that falls within the plan area (as set out in the emerging North Herts Local Plan). There are particularly high levels of growth being planned for in and around the Baldock area, as Figure 2 of the Neighbourhood Plan shows.

Policy E3 (Policy E3: Managing Construction Impacts) of the Neighbourhood Plan requires that the developments which come forward on site allocations BA1, BA2, BA3, BA4 and BA10 (i.e. the housing allocations in Baldock) limit off-site construction waste disposal.

From the Waste Planning Authority’s perspective, it is very encouraging to see that the Parish Council have included this criterion in Policy E3 and are seeking help in the initiative to reduce construction waste and subsequently help manage the high volumes of waste that are likely to arise as a result of the developments in the Baldock area.

The Neighbourhood Plan also addresses importance of new buildings being constructed in more sustainable ways.

Page 33 of The Design Guidelines (appended to the Neighbourhood Plan), sets out the fact that modern requirements for waste separation and recycling require the need for more bin storage and that it is important that adequate bin storage be incorporated into developments.

With the high levels of growth in mind (at site allocations BA1, BA2, BA3, BA4 and BA10), the Waste Planning Authority is pleased to see that the Guidelines will encourage waste segregation at its source and require developments to be designed in a way which will accommodate to a higher level of waste storage.

The county council, as the Minerals and Waste Planning Authority, would like to conclude by taking the opportunity to reiterate the comments it made in response to the Plan Area Designation Consultation in June 2017.
The Parish Council should note that the plan area contains Employment Land Area of Search (ELAS) 201 and is also located adjacent to ELAS 026. ELAS are based upon employment areas designated by District and Borough Council’s (within their Local Plans) and are considered potentially compatible with waste management uses (because they contain B2 and/or B8 uses).
There is potential for waste management facilities to come forward within these areas throughout the remainder of the life of the adopted Waste Local Plan (i.e. until they are no longer part of adopted Policy and the emerging Waste Local Plan is adopted- which is anticipated for 2021/2022).
It is also worth noting that Cumberlow Green Farm Composting Facility is situated just outside of the Neighbourhood Plan area (located to the south east of Munches Wood, along the A507). This facility is safeguarded under Policy 5 of the adopted Waste Local Plan and is also one of eight Allocated Sites identified in the adopted Waste Local Plan.

Highways

As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire whilst minimising impact on the environment. Hertfordshire County Council adopted Local Transport Plan 4 (LTP4) 2018 – 2031 which sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 will provide a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

Vision and Objectives
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority however the following comments are provided on the policies within the plan
Policies within the Neighbourhood Plan need to support LTP4 Policy 1: Transport User Hierarchy which states “to support the creation of built environments that encourage greater and safer use of sustainable transport modes, the county council will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs


Policy specific Comments
Policy G1: Improving access and parking
A parking assessment needs to be undertaken to establish an understanding and the correct balance required for additional parking to serve Baldock railway station. Any proposals for additional car parking at the railway station would have to be considered carefully as such measures can lead to increased car journeys.
Include within the policy that complementary (non-planning) measures may need to be considered such as further parking restrictions (e.g. CPZ) which is currently part of the supporting text for reason for this policy.
C) Changes to the drop-off and pick up arrangements serving Knights Templar this is unclear what you are trying to achieve and why. To support LTP4 the focus needs be on bus drop-off and not to support private vehicles.

Policy E1: Transport and air quality
This policy highlights that strategic sites in the North Hertfordshire Local Plan should not be permitted if the Whitehorse Street/Station Road crossroads junction is operating above capacity which might constitute as being severe. This however needs to be approached with a balanced view, one junction on its own is unlikely to result is a ‘severe’ impact. The Highway Authority would recommend greater alignment with NPPF which states “All developments which generate significant amounts of movement should be required to provide a Travel Plan”

Other comments
The Neighbourhood Plan does not include bus priority measures which can encourage people to travel by different modes of sustainable transport rather than private cars. It is an efficient traffic management solution which can reduce congestion/pollution in areas.
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority
Hertfordshire County Council Highways would welcome the opportunity to continue working together to develop a plan that contributes to the overall vision for Hertfordshire.

Comment

Baldock, Bygrave & Clothall Neighbourhood Plan - Submission Version

Policy E3 - Managing construction impacts

Representation ID: 8411

Received: 24/03/2020

Respondent: Hertfordshire County Council - Environment & Infrastructure Department

Representation:

See full representation.

Full text:

HCC Welcomes the opportunity to provide comment on the Regulation 16 Baldock, Bygrave and Clothall Neighbourhood Plan.

There are some rather significant allocated sites set in the forthcoming North Herts Local Plan which will have an undoubtedly significant impact on the local area. The adoption of this Neighbourhood Plan would see it become part of the development plan for this area of North Hertfordshire. HCC therefore welcomes the policies in this neighbourhood plan which build on those policies in the North Herts Local Plan, adding local context and a community minded approach to planning to ensure the best possible development for the area.

Given the environmental challenges that we face going forward and the declaration of a Climate Emergency, HCC welcomes the efforts made in the neighbourhood Plan to ensure sustainable development and design methods are used as reflected in Policy G4.

HCC Services have made the following observations and comments on the Neighbourhood Plan;

Historic Environment

We welcome this Neighbourhood Plan’s inclusion of the historic environment within its policies G5 and G6. G6 provides for local (built) heritage assets, with G5 concerned with conservation areas, and we are supportive of both.
We are concerned however, that there is no direct mention of undesignated or designated assets of archaeological interest within either policy – both dealing almost exclusively with above ground, built heritage, assets. As the Neighbourhood Plan mentions elsewhere, the area covered by this plan contains some of the most significant archaeological remains in Hertfordshire, some of which are nationally significant. As well as those areas that we know of (e.g. the Late Iron Age/Roman settlements at Walls Field and Blackhorse Farm), cropmark evidence suggests that there are widespread significant archaeological remains, perhaps also of national significance, that lie undisturbed below ground, particularly within currently agricultural areas, and within the town of Baldock itself. It should be noted that around 1800 human burials from the Late Iron Age/Roman period have been excavated within Baldock since 1925, while a minimum of 21 formal cemeteries have been identified.
Should a development have potential to impact on any potential significant archaeological remains an appropriate archaeological investigation should take place, as per NPPF para 189: “Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.” Should remains of significance be identified appropriate steps should be taken to mitigate the impact of development on the identified asset.

We would therefore strongly recommend that the wording of policy G6 be amended to provide for known and as yet unknown below ground archaeological remains within the three parishes.

Minerals and Waste

Waste
Of particular concern to the county council, as the Waste Planning Authority, is the management of construction, demolition and excavation waste. This waste stream presents the biggest capacity gap for Hertfordshire, meaning that there are significant volumes of this waste that cannot be treated in the county. Therefore, every effort should be made in the construction of new developments, to minimise waste generated throughout all phases (i.e. demolition, construction and subsequent occupation).
The Submission Neighbourhood Plan identifies the substantial level of growth being planned for that falls within the plan area (as set out in the emerging North Herts Local Plan). There are particularly high levels of growth being planned for in and around the Baldock area, as Figure 2 of the Neighbourhood Plan shows.

Policy E3 (Policy E3: Managing Construction Impacts) of the Neighbourhood Plan requires that the developments which come forward on site allocations BA1, BA2, BA3, BA4 and BA10 (i.e. the housing allocations in Baldock) limit off-site construction waste disposal.

From the Waste Planning Authority’s perspective, it is very encouraging to see that the Parish Council have included this criterion in Policy E3 and are seeking help in the initiative to reduce construction waste and subsequently help manage the high volumes of waste that are likely to arise as a result of the developments in the Baldock area.

The Neighbourhood Plan also addresses importance of new buildings being constructed in more sustainable ways.

Page 33 of The Design Guidelines (appended to the Neighbourhood Plan), sets out the fact that modern requirements for waste separation and recycling require the need for more bin storage and that it is important that adequate bin storage be incorporated into developments.

With the high levels of growth in mind (at site allocations BA1, BA2, BA3, BA4 and BA10), the Waste Planning Authority is pleased to see that the Guidelines will encourage waste segregation at its source and require developments to be designed in a way which will accommodate to a higher level of waste storage.

The county council, as the Minerals and Waste Planning Authority, would like to conclude by taking the opportunity to reiterate the comments it made in response to the Plan Area Designation Consultation in June 2017.
The Parish Council should note that the plan area contains Employment Land Area of Search (ELAS) 201 and is also located adjacent to ELAS 026. ELAS are based upon employment areas designated by District and Borough Council’s (within their Local Plans) and are considered potentially compatible with waste management uses (because they contain B2 and/or B8 uses).
There is potential for waste management facilities to come forward within these areas throughout the remainder of the life of the adopted Waste Local Plan (i.e. until they are no longer part of adopted Policy and the emerging Waste Local Plan is adopted- which is anticipated for 2021/2022).
It is also worth noting that Cumberlow Green Farm Composting Facility is situated just outside of the Neighbourhood Plan area (located to the south east of Munches Wood, along the A507). This facility is safeguarded under Policy 5 of the adopted Waste Local Plan and is also one of eight Allocated Sites identified in the adopted Waste Local Plan.

Highways

As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire whilst minimising impact on the environment. Hertfordshire County Council adopted Local Transport Plan 4 (LTP4) 2018 – 2031 which sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 will provide a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

Vision and Objectives
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority however the following comments are provided on the policies within the plan
Policies within the Neighbourhood Plan need to support LTP4 Policy 1: Transport User Hierarchy which states “to support the creation of built environments that encourage greater and safer use of sustainable transport modes, the county council will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs


Policy specific Comments
Policy G1: Improving access and parking
A parking assessment needs to be undertaken to establish an understanding and the correct balance required for additional parking to serve Baldock railway station. Any proposals for additional car parking at the railway station would have to be considered carefully as such measures can lead to increased car journeys.
Include within the policy that complementary (non-planning) measures may need to be considered such as further parking restrictions (e.g. CPZ) which is currently part of the supporting text for reason for this policy.
C) Changes to the drop-off and pick up arrangements serving Knights Templar this is unclear what you are trying to achieve and why. To support LTP4 the focus needs be on bus drop-off and not to support private vehicles.

Policy E1: Transport and air quality
This policy highlights that strategic sites in the North Hertfordshire Local Plan should not be permitted if the Whitehorse Street/Station Road crossroads junction is operating above capacity which might constitute as being severe. This however needs to be approached with a balanced view, one junction on its own is unlikely to result is a ‘severe’ impact. The Highway Authority would recommend greater alignment with NPPF which states “All developments which generate significant amounts of movement should be required to provide a Travel Plan”

Other comments
The Neighbourhood Plan does not include bus priority measures which can encourage people to travel by different modes of sustainable transport rather than private cars. It is an efficient traffic management solution which can reduce congestion/pollution in areas.
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority
Hertfordshire County Council Highways would welcome the opportunity to continue working together to develop a plan that contributes to the overall vision for Hertfordshire.

Object

Baldock, Bygrave & Clothall Neighbourhood Plan - Submission Version

Policy G1 - Improving access and parking

Representation ID: 8412

Received: 24/03/2020

Respondent: Hertfordshire County Council - Environment & Infrastructure Department

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

See full representation

Full text:

HCC Welcomes the opportunity to provide comment on the Regulation 16 Baldock, Bygrave and Clothall Neighbourhood Plan.

There are some rather significant allocated sites set in the forthcoming North Herts Local Plan which will have an undoubtedly significant impact on the local area. The adoption of this Neighbourhood Plan would see it become part of the development plan for this area of North Hertfordshire. HCC therefore welcomes the policies in this neighbourhood plan which build on those policies in the North Herts Local Plan, adding local context and a community minded approach to planning to ensure the best possible development for the area.

Given the environmental challenges that we face going forward and the declaration of a Climate Emergency, HCC welcomes the efforts made in the neighbourhood Plan to ensure sustainable development and design methods are used as reflected in Policy G4.

HCC Services have made the following observations and comments on the Neighbourhood Plan;

Historic Environment

We welcome this Neighbourhood Plan’s inclusion of the historic environment within its policies G5 and G6. G6 provides for local (built) heritage assets, with G5 concerned with conservation areas, and we are supportive of both.
We are concerned however, that there is no direct mention of undesignated or designated assets of archaeological interest within either policy – both dealing almost exclusively with above ground, built heritage, assets. As the Neighbourhood Plan mentions elsewhere, the area covered by this plan contains some of the most significant archaeological remains in Hertfordshire, some of which are nationally significant. As well as those areas that we know of (e.g. the Late Iron Age/Roman settlements at Walls Field and Blackhorse Farm), cropmark evidence suggests that there are widespread significant archaeological remains, perhaps also of national significance, that lie undisturbed below ground, particularly within currently agricultural areas, and within the town of Baldock itself. It should be noted that around 1800 human burials from the Late Iron Age/Roman period have been excavated within Baldock since 1925, while a minimum of 21 formal cemeteries have been identified.
Should a development have potential to impact on any potential significant archaeological remains an appropriate archaeological investigation should take place, as per NPPF para 189: “Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.” Should remains of significance be identified appropriate steps should be taken to mitigate the impact of development on the identified asset.

We would therefore strongly recommend that the wording of policy G6 be amended to provide for known and as yet unknown below ground archaeological remains within the three parishes.

Minerals and Waste

Waste
Of particular concern to the county council, as the Waste Planning Authority, is the management of construction, demolition and excavation waste. This waste stream presents the biggest capacity gap for Hertfordshire, meaning that there are significant volumes of this waste that cannot be treated in the county. Therefore, every effort should be made in the construction of new developments, to minimise waste generated throughout all phases (i.e. demolition, construction and subsequent occupation).
The Submission Neighbourhood Plan identifies the substantial level of growth being planned for that falls within the plan area (as set out in the emerging North Herts Local Plan). There are particularly high levels of growth being planned for in and around the Baldock area, as Figure 2 of the Neighbourhood Plan shows.

Policy E3 (Policy E3: Managing Construction Impacts) of the Neighbourhood Plan requires that the developments which come forward on site allocations BA1, BA2, BA3, BA4 and BA10 (i.e. the housing allocations in Baldock) limit off-site construction waste disposal.

From the Waste Planning Authority’s perspective, it is very encouraging to see that the Parish Council have included this criterion in Policy E3 and are seeking help in the initiative to reduce construction waste and subsequently help manage the high volumes of waste that are likely to arise as a result of the developments in the Baldock area.

The Neighbourhood Plan also addresses importance of new buildings being constructed in more sustainable ways.

Page 33 of The Design Guidelines (appended to the Neighbourhood Plan), sets out the fact that modern requirements for waste separation and recycling require the need for more bin storage and that it is important that adequate bin storage be incorporated into developments.

With the high levels of growth in mind (at site allocations BA1, BA2, BA3, BA4 and BA10), the Waste Planning Authority is pleased to see that the Guidelines will encourage waste segregation at its source and require developments to be designed in a way which will accommodate to a higher level of waste storage.

The county council, as the Minerals and Waste Planning Authority, would like to conclude by taking the opportunity to reiterate the comments it made in response to the Plan Area Designation Consultation in June 2017.
The Parish Council should note that the plan area contains Employment Land Area of Search (ELAS) 201 and is also located adjacent to ELAS 026. ELAS are based upon employment areas designated by District and Borough Council’s (within their Local Plans) and are considered potentially compatible with waste management uses (because they contain B2 and/or B8 uses).
There is potential for waste management facilities to come forward within these areas throughout the remainder of the life of the adopted Waste Local Plan (i.e. until they are no longer part of adopted Policy and the emerging Waste Local Plan is adopted- which is anticipated for 2021/2022).
It is also worth noting that Cumberlow Green Farm Composting Facility is situated just outside of the Neighbourhood Plan area (located to the south east of Munches Wood, along the A507). This facility is safeguarded under Policy 5 of the adopted Waste Local Plan and is also one of eight Allocated Sites identified in the adopted Waste Local Plan.

Highways

As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire whilst minimising impact on the environment. Hertfordshire County Council adopted Local Transport Plan 4 (LTP4) 2018 – 2031 which sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 will provide a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

Vision and Objectives
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority however the following comments are provided on the policies within the plan
Policies within the Neighbourhood Plan need to support LTP4 Policy 1: Transport User Hierarchy which states “to support the creation of built environments that encourage greater and safer use of sustainable transport modes, the county council will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs


Policy specific Comments
Policy G1: Improving access and parking
A parking assessment needs to be undertaken to establish an understanding and the correct balance required for additional parking to serve Baldock railway station. Any proposals for additional car parking at the railway station would have to be considered carefully as such measures can lead to increased car journeys.
Include within the policy that complementary (non-planning) measures may need to be considered such as further parking restrictions (e.g. CPZ) which is currently part of the supporting text for reason for this policy.
C) Changes to the drop-off and pick up arrangements serving Knights Templar this is unclear what you are trying to achieve and why. To support LTP4 the focus needs be on bus drop-off and not to support private vehicles.

Policy E1: Transport and air quality
This policy highlights that strategic sites in the North Hertfordshire Local Plan should not be permitted if the Whitehorse Street/Station Road crossroads junction is operating above capacity which might constitute as being severe. This however needs to be approached with a balanced view, one junction on its own is unlikely to result is a ‘severe’ impact. The Highway Authority would recommend greater alignment with NPPF which states “All developments which generate significant amounts of movement should be required to provide a Travel Plan”

Other comments
The Neighbourhood Plan does not include bus priority measures which can encourage people to travel by different modes of sustainable transport rather than private cars. It is an efficient traffic management solution which can reduce congestion/pollution in areas.
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority
Hertfordshire County Council Highways would welcome the opportunity to continue working together to develop a plan that contributes to the overall vision for Hertfordshire.

Object

Baldock, Bygrave & Clothall Neighbourhood Plan - Submission Version

Policy E1 - Transport and air Quality

Representation ID: 8413

Received: 24/03/2020

Respondent: Hertfordshire County Council - Environment & Infrastructure Department

Legally compliant? Not specified

Sound? Not specified

Duty to co-operate? Not specified

Representation:

See full representation.

Full text:

HCC Welcomes the opportunity to provide comment on the Regulation 16 Baldock, Bygrave and Clothall Neighbourhood Plan.

There are some rather significant allocated sites set in the forthcoming North Herts Local Plan which will have an undoubtedly significant impact on the local area. The adoption of this Neighbourhood Plan would see it become part of the development plan for this area of North Hertfordshire. HCC therefore welcomes the policies in this neighbourhood plan which build on those policies in the North Herts Local Plan, adding local context and a community minded approach to planning to ensure the best possible development for the area.

Given the environmental challenges that we face going forward and the declaration of a Climate Emergency, HCC welcomes the efforts made in the neighbourhood Plan to ensure sustainable development and design methods are used as reflected in Policy G4.

HCC Services have made the following observations and comments on the Neighbourhood Plan;

Historic Environment

We welcome this Neighbourhood Plan’s inclusion of the historic environment within its policies G5 and G6. G6 provides for local (built) heritage assets, with G5 concerned with conservation areas, and we are supportive of both.
We are concerned however, that there is no direct mention of undesignated or designated assets of archaeological interest within either policy – both dealing almost exclusively with above ground, built heritage, assets. As the Neighbourhood Plan mentions elsewhere, the area covered by this plan contains some of the most significant archaeological remains in Hertfordshire, some of which are nationally significant. As well as those areas that we know of (e.g. the Late Iron Age/Roman settlements at Walls Field and Blackhorse Farm), cropmark evidence suggests that there are widespread significant archaeological remains, perhaps also of national significance, that lie undisturbed below ground, particularly within currently agricultural areas, and within the town of Baldock itself. It should be noted that around 1800 human burials from the Late Iron Age/Roman period have been excavated within Baldock since 1925, while a minimum of 21 formal cemeteries have been identified.
Should a development have potential to impact on any potential significant archaeological remains an appropriate archaeological investigation should take place, as per NPPF para 189: “Where a site on which development is proposed includes, or has the potential to include, heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk-based assessment and, where necessary, a field evaluation.” Should remains of significance be identified appropriate steps should be taken to mitigate the impact of development on the identified asset.

We would therefore strongly recommend that the wording of policy G6 be amended to provide for known and as yet unknown below ground archaeological remains within the three parishes.

Minerals and Waste

Waste
Of particular concern to the county council, as the Waste Planning Authority, is the management of construction, demolition and excavation waste. This waste stream presents the biggest capacity gap for Hertfordshire, meaning that there are significant volumes of this waste that cannot be treated in the county. Therefore, every effort should be made in the construction of new developments, to minimise waste generated throughout all phases (i.e. demolition, construction and subsequent occupation).
The Submission Neighbourhood Plan identifies the substantial level of growth being planned for that falls within the plan area (as set out in the emerging North Herts Local Plan). There are particularly high levels of growth being planned for in and around the Baldock area, as Figure 2 of the Neighbourhood Plan shows.

Policy E3 (Policy E3: Managing Construction Impacts) of the Neighbourhood Plan requires that the developments which come forward on site allocations BA1, BA2, BA3, BA4 and BA10 (i.e. the housing allocations in Baldock) limit off-site construction waste disposal.

From the Waste Planning Authority’s perspective, it is very encouraging to see that the Parish Council have included this criterion in Policy E3 and are seeking help in the initiative to reduce construction waste and subsequently help manage the high volumes of waste that are likely to arise as a result of the developments in the Baldock area.

The Neighbourhood Plan also addresses importance of new buildings being constructed in more sustainable ways.

Page 33 of The Design Guidelines (appended to the Neighbourhood Plan), sets out the fact that modern requirements for waste separation and recycling require the need for more bin storage and that it is important that adequate bin storage be incorporated into developments.

With the high levels of growth in mind (at site allocations BA1, BA2, BA3, BA4 and BA10), the Waste Planning Authority is pleased to see that the Guidelines will encourage waste segregation at its source and require developments to be designed in a way which will accommodate to a higher level of waste storage.

The county council, as the Minerals and Waste Planning Authority, would like to conclude by taking the opportunity to reiterate the comments it made in response to the Plan Area Designation Consultation in June 2017.
The Parish Council should note that the plan area contains Employment Land Area of Search (ELAS) 201 and is also located adjacent to ELAS 026. ELAS are based upon employment areas designated by District and Borough Council’s (within their Local Plans) and are considered potentially compatible with waste management uses (because they contain B2 and/or B8 uses).
There is potential for waste management facilities to come forward within these areas throughout the remainder of the life of the adopted Waste Local Plan (i.e. until they are no longer part of adopted Policy and the emerging Waste Local Plan is adopted- which is anticipated for 2021/2022).
It is also worth noting that Cumberlow Green Farm Composting Facility is situated just outside of the Neighbourhood Plan area (located to the south east of Munches Wood, along the A507). This facility is safeguarded under Policy 5 of the adopted Waste Local Plan and is also one of eight Allocated Sites identified in the adopted Waste Local Plan.

Highways

As the Highway Authority our primary interest in Neighbourhood Plans is in relation to its approach to highway and transport matters. We aim to provide a safe, efficient and resilient transport system that serves the needs of businesses and residents across Hertfordshire whilst minimising impact on the environment. Hertfordshire County Council adopted Local Transport Plan 4 (LTP4) 2018 – 2031 which sets out the long-term transport strategy for the County to accommodate the levels of housing and employment growth being identified by the District Councils in their emerging Local Plans.

LTP4 will provide a framework to guide all our future transport planning and investment. It highlights both existing and future transport problems and issues and identifies ways we can deal with them. LTP4 accelerates the transition from a previous transport strategy that was largely car based to a more balanced approach which caters for all forms of transport and seeks to encourage a switch from the private car to sustainable transport (e.g. walking, cycling and passenger transport) wherever possible.

Vision and Objectives
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority however the following comments are provided on the policies within the plan
Policies within the Neighbourhood Plan need to support LTP4 Policy 1: Transport User Hierarchy which states “to support the creation of built environments that encourage greater and safer use of sustainable transport modes, the county council will in the design of any scheme and development of any transport strategy consider in the following order:
• Opportunities to reduce travel demand and the need to travel
• Vulnerable road user needs (such as pedestrians and cyclists)
• Passenger transport user needs
• Powered two wheeler (mopeds and motorbikes) user needs
• Other motor vehicle user needs


Policy specific Comments
Policy G1: Improving access and parking
A parking assessment needs to be undertaken to establish an understanding and the correct balance required for additional parking to serve Baldock railway station. Any proposals for additional car parking at the railway station would have to be considered carefully as such measures can lead to increased car journeys.
Include within the policy that complementary (non-planning) measures may need to be considered such as further parking restrictions (e.g. CPZ) which is currently part of the supporting text for reason for this policy.
C) Changes to the drop-off and pick up arrangements serving Knights Templar this is unclear what you are trying to achieve and why. To support LTP4 the focus needs be on bus drop-off and not to support private vehicles.

Policy E1: Transport and air quality
This policy highlights that strategic sites in the North Hertfordshire Local Plan should not be permitted if the Whitehorse Street/Station Road crossroads junction is operating above capacity which might constitute as being severe. This however needs to be approached with a balanced view, one junction on its own is unlikely to result is a ‘severe’ impact. The Highway Authority would recommend greater alignment with NPPF which states “All developments which generate significant amounts of movement should be required to provide a Travel Plan”

Other comments
The Neighbourhood Plan does not include bus priority measures which can encourage people to travel by different modes of sustainable transport rather than private cars. It is an efficient traffic management solution which can reduce congestion/pollution in areas.
The overall vision of the Baldock, Bygrave and Clothall Neighbourhood Plan is broadly supported by the Highway Authority
Hertfordshire County Council Highways would welcome the opportunity to continue working together to develop a plan that contributes to the overall vision for Hertfordshire.

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