The plan is unsound for Knebworth village as a whole, it is cumulatively unsustainable and risks creating a congested B197 housing corridor detrimental to the identity of the village and local economy. NHDC have not demonstrated how the infrastructure concerns will be met. The provisions for sites KB1-4 are wholly inadeauate.

Not justified as a better alternative is available West of Stevenage with less impact to residents across the district. Inconsistent with NPPF through allocation of significant contribution Green Belt land based on housing need alone.

Not a compliant process as changes to the NHDC documentation through the development of the draft through to submission versions has (a) excluded site KB4 until the last version and not properly included it (or the cumulative impact overall) in the modelling and assessment (b) changed the definition of Green Belt sites around Knebworth e.g. KB1 from significant to important without due reason in versions of the NHDC documents.

Not compliance as the Green Belt Review document has treated Knebworth as a town, whereas the Plan documents contradict this and treat is correctly as a Category A village. This leads to an housing over-allocation and under-assessment of the infrastructure availability.

Cumulative impact of KB1-4 plus adjacent Woolmer Green (150 houses) and Odyssey windfall (70 homes) is all known to NHDC since 2009 (see SHLAA 2009) and not considered in the Plan assessment of sites, infrastructure and its delivery. KB4 was also added in at the last minute and not assessed.

- Effects on the road infrastructure not determined. The traffic modelling assessment has excluded Knebworth and the B197 out of its scope and thus it is not adequate. The proposals in the plan (a new roundabout north of Knebworth) are wholly inadequate for the existing and planned capacity issues. Example photographs on a typical school weekday are attached to show London Road congestion.

- Ignored evidence of existing traffic congestion, this is publicly available for example from Google traffic statistical analysis. Whilst the Plan recognises the pinch point in the village centre, there are no solutions or analysis of the impact of the Plan.

- The harmful effects on the Conservation Areas through the obvious traffic patterns for the site access to KB1 and KB2, which have fundamental road restrictions which have not been assessed or considered in the site selection.

- lack of adequate schooling allocation / provision for the stated cumulative housing increases in Knebworth and immediate area including Woolmer Green and windfall

- lack of additional surgery allocation / provision for the stated cumulative housing increases in Knebworth and immediate area including Woolmer Green and windfall

- effect on the environment from and residents of KB1 and KB2 from citing homes and a primary school adjacent to the A1M, which is recognised as the most polluted and congested part of the entire motorway [ref. Highways England A1 East of England Strategic Study, June 2016].

- Effects on the local economy and village centre retail, contrary to policies SP4 and ETC2, via reallocation of site KB3 for housing only and not commercial use. In fact there is zero consideration of the local economy or retail in the Plan, despite these policies.

NHDC has deemed a threshold of 500 homes will trigger a need for a Strategic Policy. However Knebworth has 3 main sites split over only 2 landowners. There is a real risk of piecemeal development of the sites, which means that no single developer will address the fundamental infrastructure issues facing the village.