The Parish Council objects to the amount of housing development proposed for the village of Knebworth, and the lack of a strategy for the area. The four sites specified would increase the numbers of dwellings by 31% an increase which is proportionately greater than most other Category A settlements in North Hertfordshire. The rate of development proposed is well in excess of that experienced in recent decades. What has been proposed amounts to a housing "monoculture" - there is nothing proposed for local employment development.
No account has been taken of the recent planning permission for housing (70 dwellings) on the Odyssey former health centre site, adjacent to the Stevenage boundary at the Roebuck. The Parish Council notes that this site was rejected in the 2016 SHLAA Update. In addition, the Plan needs to recognise the impact of the proposal in the Welwyn Hatfield draft Local Plan (Policy HS15) for 150 dwellings at Woolmer Green, to the south of the Knebworth Parish Boundary.

The detailed concerns are set out in the responses to the individual sites, but there are cumulative effects on the whole Parish which need to be addressed. These issues are set out below.

1. Green Belt

The proposals to release land form the Green Belt are based on the Green Belt Review of July 2016. Compared to the earlier 2014 Review, this has intentionally treated Knebworth differently - as an urban area, rather than a village. Undoubtedly, this has resulted in the disproportionate allocation of housing land to Knebworth. The assumptions underlying this analysis, and its conclusions, are flawed and the Plan is unsound.

Sites KB1, KB2, and KB4 are entirely within the Green Belt which surrounds the village. Development of these areas would be contrary to Government policy as set out in the National Planning Policy Framework (NPPF). Paragraph 83 of the NPPF states that Green Belt boundaries should only be altered in exceptional circumstances.
In our view, the District Council has not demonstrated exceptional circumstances for the release of substantial areas of Green Belt land. In this part of Hertfordshire, the Green Belt fulfils many of the purposes set out in the NPPF (paragraph 80). This is acknowledged in the NHDC Green Belt Review Update (July 2016).
As part of a more widespread strategic function the Green Belt does help to check the unrestricted sprawl of Greater London along the main route corridors in Hertfordshire. This principle was established in the Hertfordshire County Structure Plan, which was approved by the Government in 1979. The NHDC Green Belt Review also considers that it contains the outward sprawl of Stevenage.

More locally, the Green Belt does prevent neighbouring towns from merging into one another. Thus the gap has been maintained between the village of Knebworth and Stevenage to the north, as well as Woolmer Green to the south.
It also assists in saving the countryside from encroachment, a particularly important function in a vibrant county such as Hertfordshire. Arguably, it has also assisted in urban regeneration by channelling economic development into Stevenage and other towns.

These points are acknowledged in the NHDC Green Belt strategic assessment of the existing Green Belt. For Knebworth, the parcels of land around the village are considered to make a significant contribution to Green Belt purposes.

According to the earlier 2014 Green Belt Review, all of the sites around the village were stated to be significant, with one exception - the land to the south of Swangley's Lane. Despite this conclusion, the sites to the west of the village (now KB1 and KB2) were recommended for allocation.

With addition of the sites to the east of Knebworth in the 2016 sites review, it is unclear why and how the District has seemed to cast aside the results of its own reports.

The Odyssey site was considered in the 2016 SHLAA Update (site 54) as unsuitable for development, in order to protect the "clear defensible Green Belt boundary to the southern edge of Stevenage". Yet this site was approved for housing development by North Hertfordshire District Council Planning Control committee on 13th October 2016 (application number 16/00813/1), thus further threatening the Green Belt gap between Knebworth and Stevenage.

2 Highways and Transport

The Parish Council is extremely concerned about the cumulative impact of the four development sites on the highways network in and around the village of Knebworth. The detailed effects are considered in the representations on the individual sites, but it is inevitable that the additional traffic generated by the proposals would be channelled onto the B197, which runs from north to south through the centre of the village. This already a busy thoroughfare, with severe congestion occurring in the main shopping centre, where there is conflict between through traffic and car parking movements. The problems are exacerbated on occasions when the A1 (M) is closed and the B197 is used as a diversionary route, also at peak times when the motorway is overloaded.

With regards to the proposals on the west side of the village, there appears to be an underlying assumption that there are three bridges crossing the East Coast main railway line, and therefore traffic movements can be accommodated with some improvements. This downplays the reality of the problems. All three bridges are narrow and cause traffic delays and safety concerns. To the south, in the Parish of Woolmer Green, there is also a fourth bridge at Bridge Road, which would also be affected by additional traffic generated in Knebworth. For any improvements to these four bridges, there would be the question of the impact on railway traffic during construction.

As cars have increased in size, it has become extremely difficult for opposing vehicles to pass safely through the bridges at any one time. The problems is particularly acute at the under-bridges at Bridge Lane and Gun Lane. It is hard to envisage how improvements could be made without wholesale widening of the structures. This would be undesirable with regards to the under-bridge at Gun Lane, which forms the entrance to the Stockens Green Conservation Area. This bridge is also located on a tight bend close to adjoining housing. Little consideration appears to have been given as to how any improvements could be delivered in terms of the impact of construction work on railway traffic on the East Coast main line.
In addition to the effects on the bridges, the Parish Council is concerned about the effects on the local roads. Much of the traffic from sites KB1 and KB2 will pass through Deards End Lane (the shortest route to the north). Traffic from these sites seeking the B197 to the south will either use Gypsy Lane/Wych Elm Lane/ Bridge Lane or Gypsy Lane/Stockens Green.

As a result of these movements, there would be a seriously detrimental effect on the character of the two Conservation Areas and the amenity of local residents. Deards End Lane in particular is a narrow hedged road with no footpath, bounded by residents' gardens. There would appear to be no viable solution to the concerns about congestion and safety.
Similar concerns are raised in relation to site KB4 and the potential impact on Watton Road and Swangley's Lane. (see representation ID278).

3. Economy and Employment

The Parish Council strongly objects to the concentration on housing development in the Local Plan proposals for Knebworth, with no provision for employment. In fact the development of the Chas Lowe site (KB3) would result in a net loss of employment in the Parish. This lack of balance is unsustainable.

4. Drainage

The Parish Council submits that the cumulative effects of the proposed developments would place severe pressures on drainage infrastructure, a problem which is acknowledged by the District Council in paragraphs 13.201 and 13.202 of the Local Plan. It is not enough to state that "scheme promoters should work with Thames Water".
This ignores the fact that the Rye Meads sewage treatment works deals with waste from a considerable catchment area. Within this catchment, there are a number of local planning authorities preparing Local Plans for submission. All of these plans contain proposals for large-scale housing development. Cumulatively, these developments cast doubts on the capacity of Rye Meads to deal with the waste which would be generated. This problem has not been addressed on a sub-regional basis. Knebworth is on the edge of the Rye Meads catchment area, and it is therefore extremely unlikely that housing could be delivered because of the real constraints on drainage capacity.

5. Impact on the Countryside

Knebworth is set within an area of attractive countryside. The village is contained within a bowl of undulating landscape. The proposed developments would cause considerable harm to this landscape setting. In doing so, large areas of productive farmland would be lost, contrary to paragraph 112 of the NPPF, which seeks to protect the areas of best and most versatile agricultural land.

6. Conservation and Heritage

The village of Knebworth has two Conservation Areas, the character of which would be effected by the proposed developments. The details are described in the responses to the individual sites.

7. Education
It is noted that the proposals for KB2 include provision for a IFE Primary School. Proposals for KB4 also contain 4Ha of land for education. Taken on their own, the proposed housing numbers on each of the development sites fall below the HCC threshold for additional school provision, which is approximately 500 dwellings. This gives rise to a concern as to whether the developers of individual sites would be willing to fund additional education provision.