The Save Rural Baldock Group – Formal Response to Consultation for North Hertfordshire Local Plan 2011-2031 Preferred Options

Background

The Save Rural Baldock Group (SRB) was formed specifically to raise awareness of the NHDC’s housing proposals and campaign for fair and reasonable local housing plans for Baldock.

It was formed in March 2013 during the initial consultation period and has worked within the Baldock community intensively since September 2014, reaching out to as many sections of the community as possible to ensure that they understand the proposals being put forward for Baldock and the surrounding area and to encourage them to take part in the consultation process.

SRB Community Activities

As well as an active website (saveruralbaldock.co.uk), Facebook (attracting 1,000 “likes”) and Twitter campaigns, the group has engaged with local people through public meetings, liaison with established organisations such as The Baldock Society and The Baldock Town Partnership, poster and leaflet distribution, market stalls, school presentations and a march which was attended by approximately 500 people. It has also embarked on a local advertising campaign, funded by some of the concerned local people, who have generously contributed the necessary funding.

Insufficient and reluctant NHDC assistance in community involvement

From the start of this process, it was clear that there was little public awareness of the NHDC plans. This was concerning given the enormous impact the plan would have on the town as a whole and the significance being placed on the public consultation stage. It is very important to give residents a fair chance to contribute a local perspective to a process that seems to be being driven exclusively by government targets and the need to comply with current regulation.

In addition to general lack of council-led advertising, the council has not made it easy for the general public to make their views heard. Most people we have spoken to find the on-line representation process daunting and complex. The council will not provide enough consultation forms for residents to complete by hand. The combination of these two factors shows a reticence by NHDC to communicate properly with local people.

Petition

SRB has collated a hand written petition of 1,006 signatures and an on-line petition with 2,111 signatures. Whilst SRB acknowledges that the names of individual signatories will not be recorded (Ref: the revised Statement of community involvement, section 4.3), the number of signatories should be considered very relevant to the consultation and reflects the magnitude of the concern that leads so many to object to these proposals. The Petitions are being submitted to the council independently of the SRB response.

Comments from Website

The revised statement of community involvement, if in fact it is applicable to this consultation despite being under consultation itself, clarifies that for comments made on social media to be considered they should be made as a formal submission to the council (Ref: the revised Statement of community involvement – section 4.4). Given the nature of the website, a wide range of commentary is posted to it, but SRB feels that some of the comments are very relevant to the debate and should be taken into consideration. We have extracted these from the site and include them here as part of our formal submission to the council. These are referenced as Appendix 5 to this document and are stored (electronically) in a separate file, entitled “SRB Website extracts for submission”.

Representations to Council

SRB has addressed the council both at the cabinet and full council meetings to make some key points about the local plan. Copies of these SRB inputs are included in the Appendices 1 and 2 to this document. We also include our open letter that was sent to members of the Council on 20th November 2014 (Appendix 3).

Communication with Planning officers and Portfolio Holder

As a local campaign group related to housing issues it is easy for SRB to be perceived as an extreme, anti-housing, ‘NIMBY’ organisation. We believe that this perception is wrong and have worked hard to show that we are a balanced, open minded and forward thinking group, ready to discuss details of the plans constructively and to be as well informed as we can be to make positive suggestions and be part of the decision making process for the town through this and future stages. We have done our best to engage with both Councillor Levett and the NHDC planning department. Attempts to hold open formal discussions and share ideas with NHDC planners were not accepted. Minutes from the initial meeting are included in this response as Appendix 4.

However, we have also met the planning officers informally, along with other representatives of Baldock town, to air some of the key issues affecting the plan. This informal meeting, held on 30th January, raised two serious concerns about the approach being taken to the consultation process.

Firstly, there is a clear reliance on public comment to drive the improvements that are needed to the construction of the plan. Officers stated that they were broadly happy with the evidence base of the plan (in spite of the glaring omissions) and would only consider enhancing it if the public consultation highlighted a need.

Secondly, there was a strong entrenchment of view that the current plan would be unlikely to be bettered by any suggestions that were going to be put forward. This should be of concern to those expecting a fair and productive public consultation.

Summary of Response

We accept that more, affordable, housing is needed and we welcome new houses being built in and around Baldock. However, the plan that has been presented to this consultation is not properly thought through. We believe that it is possible to reduce the negative impact of these housing proposals on the existing communities whilst delivering the number and type of new houses that are assumed to be needed, in accordance with the requirements as set out in the NPPF.

The draft plan lacks any vision for the future of Baldock (or any other towns). It reads as an exercise in expediency – driven by the easiest options to accommodate housing rather than creating a positive vision for our future. Whilst it appears to satisfy the necessary “box-ticking” required to meet its various legislative requirements, it does not present any rationale for the plan that is proposed.

There is insufficient evidence to support the proposals that are being made. Such important decisions should not be made without even preliminary work to ensure that the sites, particularly the major ones, are viable, deliverable and sustainable. It is not sufficient to rely on future stages of preparation of master plans to clarify fundamental principles that could completely change the underlying assumptions of this plan.

The selection of the Blackhorse Farm site, to accommodate such a large number of houses seems to be fuelled by…

 The need for the council to have a local plan regardless of what it actually proposes

 The fortunate fact that the land is owned by HCC

 Failure of earlier planning rounds, leading to a shortage of easily deliverable sites in the parts of the region that are more suited to sizable developments on the basis of proximity to centres of employment and existing transport infrastructure.

 Appearing to be the only large, relatively flat site with APPARENT good access to existing facilities such as the Baldock town centre, railway links and major road network.  It is important to note that such a statement could not be made if assessments of traffic and proper analysis of how the site is located relative to the existing town were carried out.

 The Council’s ability to collect large infrastructure fees from developers and the opportunity to build on land owned by Hertfordshire County Council.

The plan is badly thought out and we do not believe it would stand up to the rigour of an independent inspection.

The plan should take a longer-term view in order to provide robust and viable infrastructure, which can support development beyond 2031. This may well change some decisions made for the shorter term; building about half the houses required in the next 10 years on brownfield and smaller non-contentious sites that do not require large investment in infrastructure, whilst planning a new independent settlement to accommodate much of the remaining housing need. Strategic investments, in transport links as well as basic infrastructure, should be planned for where the long term benefits can be maximised, and with the whole of North Hertfordshire in mind.

We also believe that as North Hertfordshire is the home of the First Garden City, it should be promoting this blueprint by proposing that the new settlement becomes a new independent Garden City. We note that this view is similar to that of our three local MPs.

Please find below the key points that SRB would like to make about these proposals.

Detailed response

Vision and Objectives (Section 2)

NHDC have not provided a vision in this chapter. How will Hertfordshire maintain its distinctive market towns? What opportunities are there for creating desirable places to live, particularly given that we include Letchworth Garden City at the heart of our region?

The spatial strategy has not properly considered the sustainability of the major sites. In particular, an excessive proportion of new housing is placed in Baldock, where there is least employment opportunity and the greatest distance from existing major centres of employment.

Within Baldock, there has been no consideration as to which facilities will be shared with the adjoining new town and how this will be achieved, given the immovable barriers to full integration, these being the railway line, and a restricted junction at the intersection between the A505 and A507, which has listed buildings on opposite corners.

Economy and Town Centres (Section3)

The provision of an extra area of employment in Baldock rather than in Stevenage where there is a declared need does not take account of the location of the towns. Stevenage is placed on a mainline North/South railway line, has high speed access to London and easier access to the M1 motorway. Baldock will be less attractive to new businesses and increase the flow of heavy goods vehicles through the region.

Baldock already attracts outside visitors with its wide market square, attractive buildings and well established local shops. It has very few empty shops and enjoys its developing “cafe culture”, which has emerged following the recent town centre improvements. This plan should provide information about how this can be protected and nurtured given the increased number of vehicles passing through the centre of a much larger town.

This plan should also give proper consideration to how the residents of the new site will access both the town centre shops and the larger retail stores such as Supermarkets and other out of town facilities.

Countryside and Green Belt (Section 4)

SRB acknowledges the need to review the Green Belt and accepts that given the number of houses required, some Green Belt would have to be relinquished to accommodate new houses. However, the wholesale removal of enough land from Green Belt designation to meet the currently proposed housing need, without proper consultation with neighbouring areas and thorough consideration of alternatives, is not acceptable.

NHDC has not proved that there are sufficiently exceptional circumstances to justify such a step.

It is convenient for NHDC that some land in other parts of the region has not, to this point, been declared as Green Belt. This has enabled them to shelter behind an argument that they have in fact increased the amount of land in the Green Belt overall. The reality is that we have a major net loss of grade 2 agricultural land.

Perhaps most important, this particular green belt land marks the end of the near continuous urban zone of Hitchin, Letchworth and Baldock.

Transport (Section 5)

There is no proper assessment of the impact of the Baldock sites on transport.

Railway

The plan should consider impact on the railway station including access to the station and parking. The majority of new residents will undoubtedly be commuters and many will choose to drive even the relatively short distance to the station. Where will they park? Are there plans to lengthen the station platforms to accommodate twelve carriage trains which the increased commuter traffic is likely to require? Network Rail has no knowledge of any aspect of the plan which would involve improving access to Baldock Railway Station or indeed any bridges over or tunnels under existing railway lines. This does not look like a forward thinking, integrated plan.

Railway crossing

Even with the new proposed crossing point East of Baldock, there will be insufficient access to and from the Blackhorse Farm site. The existing road under the railway on Station Road is already hazardous. The footpaths either side of the road are deemed too narrow even to install a protective barrier and the bridge is so low that there are frequent incidents of lorries hitting it. This road will be used by the majority of pedestrians going to the station, existing schools and medical facilities as well as by significantly more vehicles.

Roads

There has been insufficient study of the impact of the increased population on local roads: particularly, the A 505 and A 507 which will be bound to take most of the traffic from the Blackhorse site. This plan should include thorough transport assessments of this area.

Cycling

The plan shows no thought as to the provision of safe passage for cyclists who may wish to reach the railway station and even commute to work in Letchworth, Hitchin and Stevenage to avoid motor traffic. Following the break in the Baldock/Stevenage cycle route when the Baldock bypass was built, cyclists are left to get across the bypass between cars and no tunnel was built. There is an off-road route on to the Stevenage cycle network but it is relatively rough and unlit and adds perhaps 50 % to the journey time, and is consequently little used.

It is also worth noting that action on cycling was announced on 22 January 2015. See: http://www.ctc.org.uk/news/20150122-cycling-walking-coalition-welcomes-government’s-bold-leadership-investment.

Parking

As well as additional parking needed for commuters what provisions will be made for extra cars using the town centre?

Housing and Development Strategy (Section 6)

The current version of this local plan states that the council believes the objectively assessed need for houses in the area to be 12,100. This figure is based on an out of date SHMA report and subject to a lot of contention given it has shifted dramatically upwards in recent years. SRB is particularly concerned that the detail of this local plan has been based on figures which are due to be revised within 2 to 3 weeks of the end of the consultation period. We understand that NHDC has chosen a cautiously high figure from the range of estimates suggested, to try to mitigate the risk of wholesale changes to the plan from revised numbers but, when this number gets changed along with the basis on which it is calculated, the local residents will not get an opportunity to comment until the final version of the local plan. By which time NHDC will have based large amounts of work and planning on the new number and it will be very difficult for it to be challenged.

SRB acknowledges the need to cooperate with neighbouring housing market areas. We question whether sufficient effort has been put into negotiation with neighbouring areas, which are not so bound by Green Belt regulation, to take on some of the North Hertfordshire housing need. South Cambridgeshire “have said no”. Surely that should be challenged and reported as South Cambridgeshire not complying with their duty to cooperate?

The council have not provided any evidence that they have researched all available brownfield sites. It is known that there are 400 sites about to be developed in North Herts but why have these not been counted in the proposal? This omission leads one to ask how many more brownfield sites are being ignored by the council? It is to be hoped that now the government has announced a fine for councils NOT redeveloping brownfield sites in their counties, the Council will reconsider this alternative to utilisation of precious Green Belt land.

The rate of completions in North Herts 2001-2012 (including Great Ashby) was 461 per annum. (Housing Background Paper August 2007, NHDC Annual Monitoring Reports from 2007). The construction rate imposed by the building of 12,100 houses proposed across North Herts to 2031 would be 610 per annum. We suggest that this rate of construction may be unsustainable and render the development unviable.

Design (Section 7)

SRB believes that this section should be expanded to include more information and policies about modern methods of house construction, how they can be used to build efficiently and create houses that are efficient to run (including solar), healthy to live in (insulation and central ventilation) and structurally durable.

There are lots of ‘nods’ to imposed policies but nothing to indicate any new ideas. One needs to be very careful with the latest ‘excellent’ standards of insulation. There is no mention of Combined Heat and Power, or, indeed of just what renewable sources are to be considered. Wave, tidal and hydro are mentioned, but clearly tongue in cheek, leaving wind, solar and biomass. There is not much room for wind, and biomass is becoming discredited so we must be down to solar.

Healthy communities (Section 8)

Given the number of houses that are to be built over the area and the removal of Green Belt from many sites, it is critical to ensure that houses are built to maintain green space wherever possible. SRB believes that houses should be planned to follow Garden City principles with particular care taken to ensure sufficient green space is available to everyone. The green space that is being considered as Blackhorse Farm Development is currently used for a wealth of leisure activities, often several times a day and for more than an hour at a time. Activities include walking and rambling, running, cycling and horseriding as well as frequent dog walking. These current users of the Green Belt will not be able to do so if the houses go ahead.

Natural Environment (Section 9)

SRB believes that insufficient work has been done to assess the impact of these proposals on surface water run-off, localised flood risk, water quality, air pollution, ecology and water flows, particularly, at Ivel Springs and further along the rare chalk stream it feeds. Ivel Springs Local Nature Reserve has a high risk of damage due to lack of water if the same aquifer is used to supply the increased Baldock and Letchworth populations. It has experienced three destructive droughts in the last ten years and flow has ceased each summer for the last six years. The sensitive habitats dried up completely, damaging the normal populations of animals such as kingfishers.

The farmland now referred to as Blackhorse Farm is currently home to eight of the RSPB ten most endangered species of farmland birds. The corn bunting in particular will, according to the latest research, be threatened with further decline by this development as around 10% of the breeding population of Hertfordshire lives on Bygrave Common. It is included on IUCN Red list of Threatened Species. The roadside verges into Baldock from Ashwell are the habitat of endangered species of flowers such as orchids.

This farmland is an attractive landscape, full of nature, and it provides outdoor amenity and recreation for many Letchworth and Baldock residents.

Historical Environment (Section 10)

This is much richer than indicated. Baldock may be the oldest town in Britain. This could be used positively to attract tourist interest to the area. But it cannot happen if we build a housing estate on the rest of the “Baldock Bowl”. This area stretches from the 4,000 year old henge monument discovered on the hill in Norton down across the valley of the Ivel and up the hill covering almost all of the designated housing area. It extends over the Clothall Common where previous modern building programmes have uncovered numerous ancient artefacts and many ancient monuments. To our knowledge there has not yet been a proper archaeological investigation of the proposed building sites in Baldock.

Infrastructure and Delivery (Section 11)

There is insufficient detail in this document to show that the major sites can be delivered. There is much talk of the Master plans but these are not available to the public to comment on (if written?).

The delivery of the large Blackhorse Farm site is dependent on large amounts of infrastructure being built in advance of the houses. There is no assurance that this will be done, risking years of major disruption and unsatisfactory services.

There is no discussion of the impact on a small town of rapid and large expansion, or of the many issues that will arise in terms of infrastructure and both water supply and disposal. There is also no data on current and projected traffic volumes in Baldock, which, as mentioned in the report is already suffering air quality problems and significant congestion, particularly on the only current route from the proposed development site to the town. Local schools are already filled to capacity and will be expected to cope with further expansion until new schools have been built. The doctor’s surgery is full to capacity with no possibility of taking on more patients.

It is not good enough to say that infrastraucture studies come later. They are fundamental to the acceptability of any plan for such large sites as Blackhorse Farm.

The Council have failed to show evidence that there have been appropriate surveys carried out to assess traffic concerns through and also to and around Baldock.

The A505 and A507 continue to be an expanding river of vehicles including many HGVs despite the building of the Eastern bypass. This bypass never took proper account of traffic on the A507 even at the time of building. Traffic along it has continued to increase bringing traffic to a standstill as far as Nortonbury Lane on a regular basis. The Eastern bypass was badly thought through in relation to traffic wishing to leave and join the A507 and A505 and this has exacerbated the situation.

To borrow words from Sir Oliver Heald “It seems surprising that the largest proposed site in the District is a “preferred option”, when it has not been established that there is an available access to it.”

Within the town the crossroads at Whitehorse Street and Station Rd/ Clothall Road can barely accommodate the HGVs which use it on a daily basis. Hitchin Street and other roads used as “through roads” like Weston Way also suffer in terms of congestion and safety.

Baldock (Section 12)

This town will bear the brunt of these housing proposals for North Herts, which will lead to an 83% increase in the population.

As the North Hertfordshire town closest to large areas of open countryside, it is clearly an attractive place for planners to look to place large numbers of new houses and we acknowledge that some new houses should be built here. We welcome the gradual expansion of Baldock to become a larger thriving town with the older historic centre remaining at its heart.

This cannot happen with the number of houses being proposed and the location of the Blackhorse Farm site relative to the rest of the town.

The plan does not show how residents of the new houses will live….where will they work? How will they get there? How is Baldock going to attract new businesses to set up here rather than Stevenage or Luton, in order to provide appropriate local employment?

If residents commute out of Baldock (which most of them will have to) either by rail or road there is insufficient information to show how that is going to work. The station is inadequate for all the reasons described elsewhere in this document, the roads of Baldock are already full to capacity and the suggested new ones will not alleviate the main pressure point of the existing A505/A507 junction. Virtually all traffic will end up having to pass back through the town centre, as is the case currently, causing further delay and disruption to the life of the town.

The current plan does not consider the all-round consequences of developing the Blackhorse farm site so extensively. It seems that the houses are just being placed on a relatively flat site adjacent to an existing town. This may reduce the services and facilities that the development needs to operate but shows no consideration for how it will integrate with its town centre.

If it is not going to become a proper part of the existing town, why build it so close that it destroys it. Why not put it somewhere where it can have its own identity, a fully fledged town centre and proper access to the road and rail networks?

Having accepted that it is OK to build houses this far East within the region, why not look to utilise the currently under-utilised area around Ashwell and Odsey, where the railway is underused and the road access could enable vehicles to travel North and South without going through Baldock town centre. We accept that there are issues of boundaries with neighbouring areas in order to deliver this and given the now urgent state of this region’s land supply for housing, this should be revisited.

Appendices

Appendix 1 Address to Cabinet – 24th November 2014

Appendix 2 Address to Full Council – 27th November 2014 (Full version some of which was not read out at the meeting due to lack of time)

Appendix 3 Open Letter to the councillors – 20th November 2014

Appendix 4 Minutes of meeting held with Council

Appendix 5 Extracts of Comments from website – please see separate file, entitled “Website extracts for submission”.

Appendix 1 Address to Cabinet 24th November 2014

Good evening, members of the Cabinet/ Ladies and Gentlemen,

The little town of Baldock has been shaken and stirred. Shaken perhaps by the way the council have pressed on with such a flawed housing plan. Stirred into action, knowing that we must work hard to convince councillors of the need to refuse this Draft Plan as it stands.

It is time for the Council to listen because the community are not going to take the desecration of Baldock lying down.

The part of the plan I am particularly concerned about is the proposed OVERDEVELOPMENT of Baldock. Baldock is an attractive quiet market town with population of around 10,500 and has been singled out to undergo a transformation by wholly unnatural means to a population of about 183% of its current number, that’s nearly double. Worse still this is to be managed, so we are told, by the brutal removal of the Green Belt to the north of the town to accommodate 2,800 houses.

There are three aspects of this proposal to which I would like to draw your attention tonight…

First, the effect of this proposal on the town of Baldock

We do new need housing.

Baldock is a vibrant town. We are a well-adjusted community with good community spirit. We are keen to welcome new people to the town to enable it to grow organically maintaining its identity and contributing to the diversity of North Hertfordshire’s landscape. We want to build on what we already have.

However , when I told people I would be speaking here tonight they asked me to tell you about the dire effects they believe this huge influx would have on their town. Roads, schools, doctors’ appointments, congestion, rail travel will all be adversely affected. But you will know all this from residents’ letters.

And over 2,500 people have signed our petition in agreement with this.

The building of the large edge of town development on Blackhorse Farm would spoil the character of the whole town. It would not necessarily enhance or add prosperity.

Secondly, the removal of the Green Belt.

This not just any old Green Belt. This is prime agricultural land, grade 2, tended to by several families of farmers for generations. This is good farmland where British crops are grown for the British market and which could alone sustain the population of Baldock for a year if need be. At least seven families will have to face an uncompromising change in their livelihoods and lifestyles and those of their descendants.

This is not just any Green Belt. It is part of an ancient expanse known as the Baldock Bowl, which includes a henge on the opposite hill in Norton and dates back to the Stone Age. Archaeological information as yet unexcavated is still held in the land, including probably Roman and Mediaeval material. This knowledge and inspiration will be lost if it is built upon.

This is not just any Green Belt. It is a haven for wildlife from orchids and other protected wildflowers to 8 out of the RSPB’s top ten “most wanted” farmland birds, ie in decline. Grey partridge, skylark, corn bunting, lapwing, yellow wagtail, linnet, yellowhammer and reed bunting are all in serious decline and have played an important part in our delicate local ecosystem for hundreds of years.

This is not just any old Green Belt. It is what Eric Pickles and Brandon Lewis have championed saying “Councils and local people can now decide where development should – and shouldn’t – go.”

Only today The Times Newspaper has highlighted a report from Campaign for Rural England which points out there is sufficient Brownfield land to build at least 1,000,000 houses in this country.

You cannot ignore these facts.

Thirdly, let us consider the planning process itself

Is there a definite five year plan? And if so which of the building sites in the draft plan for Baldock are in it? The reassessment of housing needs next year means we probably don’t need to even touch the Green Belt to build the five year needs.

Why is the council so set on large developments like the Blackhorse Farm sites instead of spreading them more equitably around the county? It cannot be fair to expect Baldock to take 30% of the total county’s new housing?

Why are the county council so set on taking on the burden of accommodating the needs of Luton when the National Planning Policy Framework clearly states that it should be for mutual benefit (NPPF 178)

Is this development all about money? An estimated £174 million for our Green Belt plus CIL Levy plus New Housing Funding? Will that be used to build the necessary infrastructure? Perhaps. But Great Ashby didn’t get it and are suffering the consequences.

So what is the deal here?

And that’s the truth of it. We don’t want to lose our green belt to the detriment of our green lungs or our agricultural heritage or our health and leisure pursuits, or our ecosystems and our joy or anything else because we don’t believe this is a necessary development. Over 2,500 people have already signed to agree with this.

We believe this is the council taking an easy option to tick boxes.

We ask you to be courageous and creative and reject this housing plan

Appendix 2 Address to Full Council 27th November 2014 (Full version some of which was not read out at the meeting due to lack of time)

Good evening, members of the Council, Ladies and Gentlemen

We know that you have an important job tonight.

The pressure is on to produce a housing plan for North Hertfordshire that is going to work .

On Monday, the Cabinet recommended that you approve this preferred options paper to go to public consultation, because you need to let the public have their say.

But, by passing it on to the public you, councillors, are saying that you believe this to be the best plan that the council can come up with and you are committing it to a long, formal, expensive process.

Is this really your best plan for the whole of North Hertfordshire, including Baldock?

Let’s consider the plan for a moment…

There are two very concerning constraints that have governed the choices that have been made …

Firstly, in order to be able to demonstrate that the plan is financially viable, options have been chosen that will work now, providing profits for local land owners, developers and supporting services. But this is to the detriment of longer term sustainability considerations.

And secondly, long term plans are being made on very large, potentially inaccurate population estimates that, for purposes of this plan, have been set in stone,.. but they may well change next year, before you get to the end of this process.

Please be very careful about going forward with this plan.

Look at Great Ashby…t’s a disaster…he infrastructure that was promised has not all materialized. Where are the Doctors surgeries and schools? Children are having to travel to Baldock to school every day.

We are told that turnover of housing stock is 25%…a far cry from the more normal 7 or 8 %. People are moving out.

None of us want that here. We do need to do better.

The planning process itself, is a slippery slope.

We fully understand that agreeing to put this proposal to public consultation is not approving the local plan, or granting development rights and that you are not building the houses, but it is starting to showcase possibilities which are blatantly unfair, not properly thought out and harder to change. Frankly, we had hoped for a better starting point.

Councillor Levett has said that by having a preferred options stage and putting the plans forward for public consultation, he is supporting the right for local residents to have their say, and yet we have only been given 7 weeks in which to submit comments and objections ..starting just one week before Christmas. Whilst legally, this is all that is necessary, it is not very long and the timing could not be worse. This is all the more surprising given the emphasis that is currently being placed on this public consultation.

At the very least, we hope that you will hold a public meeting before or during the consultation period. Or even better, hold some public forums where key issues can be properly debated and ideas shared.

There have already been many constructive suggestions made to the council, (which I understand will be discarded) and you have witnessed the strength of feeling that there is against these plans, not just from Baldock but also from the wider community, who can see the long term problems that these proposals could cause.

Councillor Levett has said that, during the consultation period, he and the rest of the planning team, will listen to and act on what they are told.

We will say…

– Reconsider the use of brownfield sites. We may not have enough brownfield sites to meet all our housing needs but the question is…ave we and the neighbouring areas that we are co-operating with, used all the ones that do exist?

We will say…

– Construct the plan to concentrate on what is needed – a five year plan – without trying to solve all the issues for the subsequent years. We may just be able to save some of our increasingly precious agricultural land and heritage that way.

We will say…

– Work with Luton Borough Council to try to help them solve their own housing issues. They have brownfield sites (Baldock is not taking on Luton’s housing needs directly but we are being asked to take more than our fair share of North Hertfordshire’s housing, partly because other potential sites have been allocated to Luton.)

We will say…

– If we must, for financial viability reasons, build large settlements, on prime agricultural land, let’s get it right. Let’s build them so that they can have proper access to the town they are supposed to become a part of…. or, more likely, accept that it is not practical and build a separate settlement. There will certainly be a few suggestions during the consultation period.

They really will need to listen to us.

They will be inundated with more objections, more suggestions and more, constructive debate.

Members of the council, if the only way for you to be able to consider local residents’ suggestions, is to approve this preferred options paper, then so be it.

But you really should not need to have a public consultation, in order to work out that this plan is badly flawed and unfair.

Appendix 3 Open Letter to the Councillors – 20th November 2014

The NHDC Councillors

Council Offices

Gernon Road

Letchworth Garden City

Herts

SG6 3JF

20th November 2014

Dear Councillors

It is with shock and amazement that we read the recently released draft papers, which you are due to vote on next week.

The proposal is that you should agree to allow the Housing Local Plan to include building 3591 houses round one small market town on prime agricultural land, which is currently part of the Green Belt.

How can this have come about? What possible justification would you have for agreeing to such a devastating, destructive suggestion?

The facts (taken from the proposals themselves) are as follows:-

  1. The Local Plan is based on an estimate of the number of houses that will be needed across North Hertfordshire in the next 20 years. This number has come from the 2013 Strategic Housing Market Assessment (SHMA) and the household projections from the Department for Communities and Local Government. This is not set in stone and will itself be subject to review within a year (i.e. before the proposed submission draft of the local plan is due in September next year). Current estimate 12,100. This has been massively revised upwards from 7,500. Why? What assumptions have been made to set this monstrously large figure? How can such a momentous decision be based on such flaky data?
  2. The plan dismisses Eric Pickles’ recent statement about use of Green Belt as nothing more than a statement of the existing policy, and therefore it has been ignored. Please remember what he said…

“The Government attaches great importance to Green Belts. The fundamental aim of Green Belt Policy is to prevent urban sprawl by keeping land permanently open… Inappropriate development is, by definition, harmful to the Green Belt and should not be approved except in exceptional circumstances.”

The Green Belt review has been commissioned by NHDC with the Local Plan in mind but is still subject to review and approval by you, the councillors. These are NOT exceptional circumstances.

  1. The pressure to change the Green Belt boundaries has only come about because planners have failed to find any other sites to build on easily. The council has a duty to cooperate with neighbouring areas where they are unable to fulfil their own housing requirements. This is not a duty to accept those extra houses at any cost. If a sacrifice has to be made it should be revisited on the original area where the shortfall was identified rather than irrevocably left with the neighbour.

There are two key decisions that should be reconsidered very carefully.

  1. Luton’s Local plan, which is itself only at the consultation stage, identified that it was unable to meet its own housing requirements, in part because it is deemed too expensive to build on their own brownfield sites. North Herts has agreed to take on 2,100 of Luton Borough Council’s housing. So, we have to find 2,100 houses elsewhere within North Herts.
  2. The council have had a tough time working with Stevenage Borough Council over a site in the west of the A1. Rather than tackle the issue they have taken the easy way out by saying that they will leave this site for Stevenage’s possible future needs. So we lose space for 3,100 houses that could have been used for North Herts needs.

So that is a further 5,200 houses that have to be found in other parts of North Herts.

  1. In order for this suggested Local Plan to be accepted, the planners have removed Green Belt from around Baldock. This contravenes 3 of the 5 functions of the designation of the Green Belt.

To assist in safeguarding the countryside from encroachment;

To preserve the setting and special character of historic towns;

To assist in urban regeneration by encouraging the recycling of derelict and other urban land.

The remaining 2 have been upheld by redesignating parts of the land between Hitchin and Luton as Green Belt. These being

To check the unrestricted sprawl of large built-up areas;

To prevent neighbouring towns merging into one another

This is welcomed but does not mitigate the decisions that have been made in relation to Baldock.

  1. The allocation of houses is extremely disproportionate across the District. While Baldock gets 30% of the total, Hitchin & Letchworth (both more than three times the size of Baldock) only get 11% & 17% respectively. While the population of Baldock will double in the period 1991 – 2031, Letchworth will increase only by 16%. This is simply not fair and will destroy the character of a beautiful Georgian Market town.

Your constituents voted for you because they have faith in you and trust you to do what is right.

Destroying grade 2 agricultural Green Belt land is simply not right.

We urge you to reject the Local Plan on 27th November.

Yours sincerely,

Save Rural Baldock Group

Appendix 4 Minutes of meeting held with the Council

A meeting was held on 22 December, which was intended to be the first of several where the details of the local plan could be openly discussed with the planning team. The planning officers were reluctant to attend and no further formal meetings took place.

An informal meeting was held on 30 January attended by David Levett and three planning officers, who responded to questions from SRB and The Baldock Society. It is of great concern to us that, despite the acceptance by David Levett in earlier meetings that the plan was flawed and needed further evidence to support it, the planning officers made it clear that they were happy with the level of the detailed evidence in the plan and would only consider further assessments if the representations that they received during the consultation indicated that it was necessary. It should not be left to members of the public, who cannot be expected to be experts in planning, to have to point out basic inadequacies of such an important document.

(detailed minutes not included here)

This entry was posted in Uncategorized. Bookmark the permalink.

One Response to The Save Rural Baldock Group – Formal Response to Consultation for North Hertfordshire Local Plan 2011-2031 Preferred Options

  1. Richard Sell says:

    This is brilliant. Well done – and a huge thanks – to all involved in putting this response together.

Leave a Reply