Knebworth

I am writing to oppose the proposed submission by NHDC regarding the Local Plan 2011-2031 and in particular the sites identified for development in the village of Knebworth.

As a resident since 2009, a commuter into London and a local school mum using village roads, there are several reasons why I object, all based on personal experience as set out below.

SOUNDNESS

I do not consider that the plan has been based on a strategy which seeks to meet objectively assessed infrastructure requirements which are consistent with delivering and achieving sustainable developments. The road and rail network is already over-crowded for a village population of 2000. To increase the population by 33% without transport modelling to give evidence that NHDC can deliver improved and long term sustainable infrastructure improvements fails to meet basic requirements of both the plan and residents. Supported by the following cases:

* Knebworth's roads - the B197 is always used to by-pass the A1M in the event that the motorway is shut or has reduced lanes due to an accident. Traffic queues from as far back as Woolmer Green all the way through to Junction 7 by Knebworth Park (3 miles). The centre of Knebworth has time limited parking on both sides of the high street which restricts the width and often forces traffic to queue while vehicles use the high street in single file. The B197 is a main bus route and no consideration has been given to the impact of more commuters, either requiring additional bus services which will increase traffic flow or to the increased number of cars for 600+homes which will have the same effect. Access under the railway bridge by Knebworth station is single file and the footpath dangerously narrow underneath the bridge, particularly for parents with buggies who use that path often on the way to and from school. Swangley's Lane is a narrow country road with a sharp and dangerous bend just beyond Swangley's Farmhouse; there is no footpath along this road beyond Knebworth primary school. Watton Road (which I use four times a week for school runs) has speed bumps and only single file traffic due to residents parking on one side. Because Hertford Road was closed as a through road it has since forced traffic through Knebworth, specifically along Watton Road. Oakfields Road (where I live) is fully occupied by cars at weekends on one side of the road from visitors to the recreation ground when its car park is full (the recreation ground has two full size and two junior size football pitches used on both Saturdays and Sundays, 4 tennis courts, a playground, a basketball pitch and a bowling green). The village cannot sustain more traffic and there are no provisions for widening the roads.
* Rail services - there are only 2 trains an hour (except 3 during rush hour) but there is currently a proposal by Thameslink Govia to reduce the number of trains even further. I commute into London 4 days a week and will testify to already overcrowded trains which necessitate standing only during peak times. Knebworth has a significant commuter population, currently served by fast trains to/from King's Cross in peak times, but removing fast train services will lead to even more overcrowding and endanger public safety, even force out commuters from the district. An example of overcrowding is the 18.43 from King's Cross to Knebworth on 28/11/16. The train was not going to stop until St Neot's so commuters relocated to the departing 18.52. At Welwyn Garden City, where the 19.27 train divided from 8 to 4 carriages, a separate train ended service and the commuters piled on to the 19.27. Some could not get on. The train continued, 15 minutes late to Knebworth. This was not a one-off incident and since the line was assigned to Thameslink the service has deteriorated and is set to deteriorate further with fewer trains.
* Higher population will require more bus services. These will further reduce traffic through the village centre and along the B197 to Stevenage.

I do not consider the plan to be the most appropriate strategy when considered against reasonable alternatives.

* There is no evidence that the proposed 33% growth of Knebworth housing can be supported by the current infrastructure and absence of any transport modelling plans.
* GP surgery - it is already impossible to get a doctor's appointment at Knebworth Surgery on Station Road within 3 weeks, unless for an emergency. The surgery is over subscribed or under staffed and it is not possible to provide adequate services to additional residents of the village should the proposed developments go ahead. With the recent addition of a care home and retirement village in Knebworth I expect that home visits for the Knebworth Surgery GPs will only increase over time. The proposal for a surgery on the site of the existing library is for a replacement not an additional surgery and public health is therefore at significant risk from the proposals.
* Development of site KB4 would remove a vital wildlife habitat from a green belt area. The agricultural land is actively farmed all year round and living close to the fields I have first hand evidence of 2 to 3 crop rotations per year. The fields provide valuable and safe tracks for dog walkers and runners, something which surely must be considered given the absence of footpaths and high density traffic along several main roads in Knebworth.

I do not consider the plan to be deliverable based on effective joint working on cross boundary strategic priorities.
* There is no account in the plan of the need for highways, sufficient secondary and primary education facilities or health facilities to support the proposed development in Knebworth.
* There is no consideration given to educational needs, either for a secondary school for the current population (the nearest secondary school being Stevenage) or for an additional primary school. Class sizes at the primary school are already 30 with a dual-class entry in Reception. Facilities at Knebworth primary school are already over crowded and in need of modernising. Educational and PSHE requirements cannot be delivered in the absence of a sustainable educational plan for Knebworth's expansion.
* There may be a need to deliver housing by 2031 but the aggregate number of houses across all 4 proposed developments in Knebworth places enormous strain on a small village and significant risks to the existing and new communities.

LEGALITY

* KB4 has never been submitted before to the community as a site being considered for development. I do not think adequate pre-consultation work has been undertaken on this site and I believe the Council has failed to adhere to the legal compliance criteria as stated in the Council's Statement of Community Involvement.
* The National Planning Policy Framework states that local plans must be supported by local evidence base yet I do not consider the local needs to have been objectively assessed and, instead, to have been left unconsidered while the Council identifies potential sites in order to meet Government set housing quotas. There seems be no cooperation across local authorities with each developing local plans in isolation rather than collectively.

For all the reasons above I do not consider the local plan to be positively prepared, justified, effective or consistent with national policy and because of the detrimental and enormous impact it will have on Knebworth I wholeheartedly object to the proposal and feel it should be withdrawn.

I am writing to voice my opposition to your local development plan, specifically with regards to the so called development plan of the village of Knebworth.

Firstly, I wish to address the issue of road links. The school run to the outskirts of Welwyn Garden City used to take us 20 minutes. It now takes us 40 minutes on a good day and frequently takes us 50 minutes - to drive 2.5 miles!!!!!!!!! We now have to leave home at 7.55 whereas school doesn't start until 8.50. This situation is getting worse each month, without the additional strain of 663 houses added to the mix. The road infrastructure simply cannot cope. Especially if Woolmer Green takes on additional 150 homes. There are no alternate routes - the country lanes often cannot allow 2 vehicles to pass, others have huge potholes on the verges where you are able to pass, all are unmarked and have no street lights, deadly curves and high hedges, severely limiting visibility especially in winter when the dark and frost set in. As the A1 (M) is very frequently slow between Stevenage and WGC, it seems that many commuters from Stevenage take the B197 through Knebworth in order to avoid that gridlock - there simply is not the capacity right now - never mind in the future.

Secondly. Knebworth Primary already is full to capacity, an additional primary school built right next to the A1 (M) would have to be very large in order to accommodate the current overflow plus the future population. Notwithstanding the air pollution and the very negative health impact this would have on primary aged children, it doesn't address the fact that the ENTIRE current population already has to farm out their children to secondary schools in the surrounding towns, whether that be Stevenage, WGC, Ware, Hertford, Hatfield etc.. Hence more traffic.

Thirdly. Green Belt. I'm absolutely horrified that ALL of the proposed housing would be built on green belt land. This is exactly what makes Knebworth Knebworth. The fact that it is surrounded by rolling green countryside which is very much valued by all of us in Knebworth. Where does this kind of expansion end? It doesn't. We would end up being swallowed up by Stevenage, and that is anathema to everybody who lives here. We do not want to be part of an amalgamation of the Greater Stevenage Area. From what I understand, the removal of this green belt around Knebworth, which protects the space separating it from the surrounding towns and villages actually VIOLATES government policy .There is absolutely no justification for this infringement when Stevenage already has 3100 new homes in the pipeline on west land. If NHDC really need to build an additional 15950 homes, then surely a new Garden City with the appropriate infrastructure built to design and from scratch would be an infinitely more intelligent choice. A more difficult choice perhaps, but I would suggest that local residents would be very much more in favour of this option if proper and public consultation were to be implemented. The other option, and the one currently being blindly pursued, is to ruin rural Hertfordshire villages - Knebworth, Codicote, Baldock, the list goes on......it is senseless and entirely unnecessary. These villages then become towns. Which means that this area, once quaint and pretty, with independent quirky villages will become a series of characterless dormitory towns. That's what you are going to create. Well done.

Fourthly. Rail Links. The future changes seems to be a bit opaque to say the least, but clearly we will be losing high speed trains into King's Cross. Not great for many of my neighbours or for myself.

Fifth. We would lose much of what makes the area so attractive. Open landscapes, loss of countryside and farming land. Not to mention our Deard's End Conservation Area, Knebworth Woods site of special scientific interest, Stockens Green Conservation Area. Surely these areas were labelled as such specifically in order to BE protected????

My children and I moved here in 2013 from abroad, as we wished to resettle in the UK, my country of birth and origin. We chose Knebworth specifically because :

-it is a village with plenty of green areas (our house backs onto a field) and woodlands that we so desperately needed -it offers an easy commute into London King's Cross -it is a relatively tranquil village with a good high street and an easy drive to both Welwyn Garden City and Stevenage -i do not have relatives in the area and that was never a consideration

Implementation of your plan would mean that:

-our village would lose an awful lot of it's green areas - our back field would start being built upon and many of our green conservation areas would be lost -our landscape of green fields would be lost forever -commutes to the city would become longer -it wouldn't be a village anymore but a noisy gridlocked commuter town, with absolutely horrific traffic in either direction -absolutely no improvement in infrastructure or amenities to offset any of the negatives -I would probably not want to live or pay taxes here anymore

In all honesty, I can't find anything at all that would have an even remote benefit to the local community.

I have spoken. I hope somebody is listening as it seems that we "the people" no longer get heard.

I am writing to express my opposition to the proposed housing development plan for Knebworth.
As I am sure you are aware the plan makes provision for over 500 houses to be built on designated sites in and around Knebworth including green belt land.
My opposition to the plan is based around access to those sites, increase in traffic congestion and the existing infrastructures inability to support the proposed growth.

Access:
I hope you will see from the following that the access and traffic issues are interwoven.
Knebworth has one main road that runs through it from Stevenage A1 Junction 7 to Welwyn A1 Junction 6 this road is the B197. At present it can be extremely difficult to get through the High Street. Other access roads to the village are Old Knebworth Lane, Deards End Lane, Gipsy Lane, Swangleys Lane, Gun Road, Station Road and Watton Road. With the exception of Watton Road which is itself narrow, all these roads are for the most part single track or at least very narrow roads. The proposed sites would have these roads as their access routes. Given that these roads are narrow, Station Road, Gun Road and Gipsy Lane (Bridge Road) also have mainline railway bridges that provide the bear minimum of pavement space on what are the main routes for parents taking children to the local schools. Deards End Lane also has a railway bridge with extremely tight turns at each end of the narrow roadway.
The current levels of people using these roads causes congestion. The restricted access to the village has not been accurately assessed and the sites suggested are not suitable.

Traffic:
The existing proposal states that the high street does not appear to present any problems with regard to it being a bottle-neck when there is traffic congestion. I would like to point out that even on a good day the High Street can be backed up with morning and evening traffic, add to that the visitors to the shops I think you can understand that at present It does represent a traffic problem. It may be worth asking the drivers of the Buses, 300 and 301 for their professional opinion on the road and times of congestion.
That is day to day traffic in the area, if you consider days like today for example (November 28 2016) where there was traffic congestion on the A1, the only way through to Stevenage is via the B197 of which Knebworth High Street forms part. There was gridlock on the surrounding roads. This is not an opinion this is a fact. All these issues exist with the current levels of traffic in the village if you factor in car owners from a further 500 new houses making work, school runs and shopping trips it becomes very clear that there would be future traffic issues.
There is an issue with traffic in the village and surrounding roads, the proposed development will add to this.

Existing Infrastructure:
Apparently the proposed development will address improvements to the local infrastructure. At present there is restricted access to the village, the existing levels of traffic cause congestion, the mainline train station is overcrowded at peak times as the platform is too short to allow the longer trains to stop, there is not adequate provision for parking for either the train passengers or visitors to the village shops, amenities or school. Building 500 new houses will not alleviate the existing problems with local infrastructure but will in fact add to them. During recent years the village has suffered from serious flooding this has been due to run-off from surrounding lanes, fields and the nearby A1 with the existing drainage system being unable to cope as the drains constantly block. The plan is to build houses with drainage that will cope with the local flooding issue. This great planning for them but unfortunately does not address the existing problem in the village.
The proposed development does not address the needs of the infrastructure in order to cope with an extra 500+ households in the village.

I understand that there is a need for housing but I am fearful that the project will just be rubber stamped under pressure from developers and central government.
I would strongly urge you to consider the points raised and I hope you will agree that the area is not suitable for such a development.

I am a resident in Knebworth and have lived her for 22 years. I would like it to be noted that I object to the building of any more houses within the village. I have a family who are looking for housing but they also feel Knebworth does not have the ability to take on more housing, people.

Please can my objections be noted.

I wish to make comments with regards the planned housing explosion in Knebworth. This is a community that is already over populated for the amenities provided. My main concern is the increase in road traffic. At present anyone living in the south west of the village uses Deards End Lane as a cut through to avoid the village. This is a narrow winding lane with no pavements. As a peconon driver living in the lane I walk daily from my home. This has become increasingly dangerous in recent years. If you are intending to build an extra 600 houses in that area the traffic will make walking impossible virtually imprisoning older residents.
I would also add that there is, effectively, only one road into and out of the village. Apart from the B197 there are only lanes winding across country to no where in particular. Over the last year or so the B197 was closed due to accidents leaving the village cut off to the north. Should anyone have required the emergency services then they would have been out of luck.
If houses must be built in Knebworth I would suggest land on the other side of the motorway where there is room to put a road through to join the A1M.
I understand that plans are in place to close the railway station in Knebworth which would make this a less popular area for people to move into. Also the school is over subscribed, the surgery unable to cope with the number of people requiring appointments. The pavements overgrown with brambles and roads full of potholes. It is surely time North Herts DC stopped treating us as a forgotten outpost remembered only when collecting council tax. Oh and when foisting unneeded housing on a small village.

I do not object to the creation of new housing. People have to live and work somewhere.
What I do object to is the planning proposals for all the villages and towns on the A1 corridor and Knebworth in particular.
The proposals make scant reference to the major difficulties for the infrastructure that will present themselves as a result of increased numbers of people, increased demands on services, and increased travel expectations.
Recently I was contacted by Affinity Water and was informed my property was to have a water meter installed. In the correspondence from Affinity Water I was informed that the provision of clean water was at a CRITICAL stage, hence the need for a water meter. The Local Plan has not addressed how this situation will be addressed with the increase in households that are being proposed.
The Local Plan does mention increased traffic will result, acknowledging that Knebworth is a 'pinch point' at certain times. I doubt whether the author of this report has ever travelled on the B197 as it makes its way towards the A1. There are many pinch points which occur all along the road and at many different times of the day. Given the extra housing that is being proposed for Knebworth, Woolmer Green, Codicote and all villages and towns north, the B197 will soon be at a standstill. Given the problems that occur around Junction 6 of the A1, the B197 is already a 'rat run'. Increased traffic will destroy the heart of Knebworth village.
As there is no provision for employment opportunities in the Local Plan, one can only assume all inhabitants of the new houses will therefore be commuters. Knebworth already suffers from commuter parking as can be witnessed by the number of times the issue has been raised at Parish Council meetings. There has been a 70% increase in the use of Knebworth Station by commuters. There is no mention in the Local Plan how the train companies will cope with a 30% increase in Knebworth's population as well as increases in the other villages' population who regularly park in Knebworth and use the station.
No mention is made in the plan about how local services will be affected and how the issues will be addressed. Mention has been made about local schools but as the suggestions, for a local primary school, for example, are not binding or funded then it is more than likely this will be ignored. No mention is made of the difficulties extra housing will create for GP surgeries or hospitals etc.
It seems to me that the Local Plan has been shoddily put together; housing developments have been sprinkled across the North Herts area and no coherent strategy has been put forward as to how this will affect travel, public services, employment and, tragically, the Green Belt.

I would to register the following concerns to the proposal for 663 dwellings in Knebworth over the next 15 years:
1. Traffic congestion
As an essential car user for my employment (Rapid Response Occupational Therapist) in St Albans, I have no alternative but to drive to work along the B197 out of Knebworth. Furthermore our children take the school bus from Knebworth to Stevenage. When there is an incident on the A1M between junction 6-7 , north or southbound, all traffic is routed through Knebworth, resulting in an already busy road coming to a standstill. This means that drivers/students are very late to school and work.
An additional 663 dwelling will result in many more cars but there appears to be no strategy to deal with this increased demand on the roads leading to and within Knebworth.

2. Health and social Care facilities
It is common practise to wait 2- 3 weeks for a routine GP appointment and many more weeks for a routine hospital appointment. Social care in the area is at breaking point with vulnerable patients waiting weeks for an assessment and then a suitable package of care.
The residents in the proposed dwellings will have health and social care needs but there is no plan to increase health and social care provision in North Herts.

3. Schools
The plan provides for an additional primary school on site KB2, but there is no plan for an additional secondary school. It is currently difficult to get into secondary schools within the area.
An additional 663 dwellings will house students in need to secondary school places these students will put more pressure on existing places. The local plan does not provide additional access to secondary schools.

4. Public Transport
Commuter trains at peak times are usually full and many people who have paid for expensive seats stand from Knebworth to Kings Cross.
The new dwellings will house commuters who will put additional pressure on current trains. Although there is currently a GTR consultation details proposed changes to peak hour trains, these do not appear sufficient for the additional commuters these properties will house.

5. Greenbelt land
Three of the proposed sites (KB1, KB2, KB4) are on Greenbelt land, with sites KB1 and KB2 on designated conservation areas. There has already been substantial growth in Knebworth over the last 10 years (Knebworth Gate, the Lytton Field houses)
It is national policy to protect land within the Green Belt (See - 'planningguidance.communities.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/9-protecting-green-belt-land' [accessed 29/11/16]) . However the Local Plan proposes the removal of large areas to the East and West of Knebworth. The local plan therefore contradicts National Planning policy.

I would be grateful if you could register my concerns and reply as soon as possible.
Thank you for your time and assistance

This email is to state my opposition th proposed housing development of over 500 new houses in and around Knebworth as part of the North Hertfordshire Local Plan.
I would like to oppose the plan for the three reasons as laid out below.
1. Poor access
Due to the extremely restricted access to all of the proposed sites, most of which are accessed via single-track or narrow roads, the area will suffer from further traffic congestion. The main access roads within the village are: Swangleys Lane, Gipsy Lane and Bridge Road, Deards End Lane, Gun Road, Station Road, Old Knebworth Lane and Watton Road. Of these roads Watton Road is the only one that is not single track but is itself extremely narrow. All of these roads become very hazardous or blocked when there is snow, Gipsy lane and the railway bridge at Watton Road have often flooded and become impassable.
The development plans have not taken these factors in to account in their selection of sites as these sites are clearly unsuitable.
2. Unsustainable increase in local traffic
The village already suffers from traffic issues including the bottle-neck in the High Street which is the main through road in the village. This bottle-neck occurs in regular traffic with morning and evening commuting, school runs, visitors to the shops and amenities, bus routes and business deliveries.
Whenever there is a problem on the A1 motorway the only link between Junction 6 and Junction 7 is the B197 this increase in traffic causes complete gridlock in the High Street and surrounding streets.
Add to this the prospect of 500 plus new households to the area and it becomes very clear that the development plans are not suitable for the area.
3. Over burdened infrastructure
The local plan does not make provision to improve or even shore-up the local infrastructure problems which include poor parking facilities for the train station and the local shops, an overcrowded train station unable to cater for the present level of passenger numbers, with a short platform that due to financial constraints could not be upgraded to allow for the longer trains needed to stop at the station in order to cope with numbers. Also the village has suffered with serious flooding in the past due to a drainage system that was designed to cope with the 1970s housing developments but which fails to handle the run-off from surrounding fields and roads which in turn causes flooding further into the village.
The plan would overburden the existing infrastructure which is at present inadequate. The development plan is unsuitable for Knebworth.
I would be very grateful if you would consider these points as they not just opinions they are the facts about life in a rural village that could not support a plan forced upon it because of the financial interests of developers and the poorly advised decision makers in central government.

I have several objections regarding the North Hertfordshire District Council Local Plans, these are summarised below:

Overall I am concerned regarding the impact on the whole district and particularly our village, Knebworth. However I am more concerned at the total picture of proposals to further develop neighbouring Codicote and Woolmer Green too. The plans show no infrastructure work, no joined up planning with highways, rail services, local ammenities and contain no reassurances that they provide any benefit to the areas affected. I fundamentally object to residents feeling the need to object rather than planners planning effectively and positively.

Why is there not a proposal to effectively plan with all councils in the area to build a new garden city, which in the long term would improve quality of lives and provide jobs. I understand this has been called for by local MP's and I believe it would gain support not objections from thousands of local people including new residents .

My objections are not personal they highlight issues that will affect current and new residents.

Objections

Errors in the plans and planning process - contravene Government guidance
The number of houses in the plans contravene actual Government Guidance of the number of house built as 30 per hectare but the actual number being built by developers is far greater sometimes up to 40-50 per hectare. The NHDC Local Plan has failed to correctly calculate the number of houses. The fact is that there will be a significant increase in the number of homes built in the Local Plan than have been proposed. Therefore, suggesting the Local Plan has allocated at least 45-50% more land than is required. There is no need to develop on Green Belt sites around villages which do not have the infrastructure. Also there were late additions to the plan and therefore there was not a proper consultation procedure.

Building on multiple Green Belts - the plan conflicts with national Green Belt Policy.
The proposed new sites being built on greenbelt will have impacts on the Countryside and wildlife, loss of trees and nature, impact on public footpaths and quality of village life. As well as natural drainage and soak away.

Transport Infrastructure issues - the plan is not consistent with National Policy Section 4 "Promoting Sustainable transport"
The current road infrastructure is village roads linking villages. To increase housing to the levels proposed in each village has a cumulative effect and stresses this network. One only has to consult sat nav systems to see the current level of congestion on the local roads. With a potential of 50% increase in cars (probably more as each new home will typically have more than one car) doing work and social journeys across the area is a big step change in volume. The costs to councils of repairing already worn out pot holed roads will increase significantly, a short sighted approach is evident. Narrow, often one car width roads, with pull ins can not support this increase in traffic and will become dangerous. There are already choke points on the roads in rush hour and this volume increase will result in areas of complete grid lock. The increases in car pollution too are an issue. The plans include no proposals to improve the road network, which is a major planning shortcoming. That is not to mention the impact of large HGV's, work and trade vehicles that will be associated with such a large building projects. The Clock Towers development caused problems . A specific example of over development is in Watton at Stone where the main road is now used for residents parking and is very dangerous outside the Watton station.

One very important point involves plans /or lack of plans for the railway stations. Knebworth , Stevenage, Watton At Stone and Welwyn North are already at parking capacity and not in walking distance for many of the passengers and the proposed rail plan proposes fewer fast services to London from Knebworth , evidence of no joined up thinking or consultation. There are no plans for any extra parking at Knebworth station which is already not serving the demand. Why would one build houses on a plot right next to the railway, what is needed in the plan is affordable station parking. There is no such provision and why does planning not work with the rail provider to encourage increases in services for a route that is planning to have a significant increase in demand? Specifically over 600 new homes and that's not including the other village increases that use Knebworth station.

Flooding - The plan does not adequately address flooding issues and logically more hard standing and foundations means less run off, more flash flooding .

Thames Water have spent over £4m investigating drainage in the area, these villages have high water tables and are already prone to flooding, building of so many new sites will directly result in more pressure on the village drainage networks, leading to flooding, resulting in more traffic congestion problems , more pollution and road damage.

Village amenities - the plan over stretches current provisions
Local employment will be lost in two of the proposed sites Chas Lowe (Knebworth) and Wyevale (Codicote). In addition many elderly, disabled and families enjoy local community events and value for money dining at Wyevale .Lack of plans for schools, doctors all inadequate for the proposed increase in population. Bridge Cottage Surgery Welwyn, Knebworth and Watton surgeries are already full and it is difficult to secure appointments. I presume Doctors have been consulted..The plans seemingly rely on the currently overstretched services to support new residents which is an issue.

This plan causes more problems than solutions for current residents and indeed future residents.

Under these circumstances I object to the plans , they are not holistic and are muddled. I support a new Garden City or Cities which should be developed to meet future housing needs at the same time developing public services and provide employment opportunities and transport networks for the new community, which is an option not even referred to or explained why its a poorer option than this one.

I am objecting to the proposal to build 663 dwellings on the Green Belt around Knebworth. This is around a 31% increase on the current size of the village and there is insufficient infrastructure or services capacity to cope.

Travel and Parking

* The B197 is permanently busy. Traffic is very slow moving, frequently at a standstill, from early morning and all through the day. Queuing traffic and pollution is a real problem. Residents often cannot access the B197 from the side roads due to the amount of traffic.

* When there is an accident or breakdown on the A1(M), the B197 becomes even worse, crawling traffic for hours on end. Years ago there were plans to widen the A1(M), but these were shelved even though the problems were well known.

* Many of the housing proposals within North Herts will make traffic flow along the A1(M) even worse. Thousands of extra commuters will need to join the current traffic jams.

* The three bridges in Knebworth make driving within the village a problem even now. Extra housing will make this worse. These are very narrow bridges especially for modern cars. There is another narrow bridge south along the B197 in Woolmer Green where they recently narrowed down the road, making traffic much slower.

* Rail travel from Knebworth has increasingly got worse. Commuters come in from areas around Knebworth to use the train station. The trains are packed, often with standing room only. There were plans to put extra tracks in and widen Welwyn viaduct, but these seem to have been shelved. It is a problem that has been known about for years.

* Parking is made worse by those travelling from out of the area to commute using Knebworth train station as their starting point. There is not enough parking for current users, the additional proposed housing would make train travel unbearable, perhaps even impossible. Local roads have cars parked from very early morning, all through the day. This makes life difficult for local residents.

* Parking is also a problem in the village centre, but the local traders need people to be able to park and visit their shops to keep them going. Parking issues could be improved slightly if NHDC allowed and hour's free parking in the car park of St Martin's Road.

* The infrastructure problems in Knebworth have been known and growing for many years. It is time that NHDC addressed the issues and tried to solve them rather than add to them.


Environment and Services

* The housing proposals are huge and would mean the loss of Green Belt around the whole of Knebworth. The three largest proposed sites are in the Green Belt. I understood government policy is to protect the Green Belt, so this does not make sense.

* The character of the whole village would change with losses of open views, productive agricultural land and a separate identity.

* There is a danger that Knebworth would merge with Stevenage and/or other settlements along the whole B197.

* Doctors, dentists and the school are all struggling with being over-stretched. Additional housing would make all these worse.

* I understand there have been issues in the past regarding effective sewerage services and constraints connecting with Rye Meads Sewage Works. I don't think this has changed.

* Knebworth has a long history of water run-off and flooding over the years. There have been issues recently with flooding at the cemetery on the edge of the village and there is often standing water on the proposed KB4 site. This is currently productive agricultural land. Building houses would increase the flood risk.

* The two other large sites are both accessed via narrow bridges and are near to established conservation areas one side and the motorway the other side. There would be pollution issues in these cases.

* NHDC have land available for over 3,000 houses to the west of Stevenage which they now no longer wish to consider, instead going for the easy option of putting houses in all the villages without taking into account the implications. They do not seem to have considered the infrastructure, environment, local employment, Green Belt or residents' quality of life, even the new ones who would occupy the new houses. This land has direct access to the motorway and would be a better option for housing development than Knebworth and other North Herts village sites.

I wish to register my opposition to the above proposal to increase the size of Knebworth village by a further 598 homes as I believe it to be unsustainable for the following reasons.

There is a lack of joined up thinking in the NHDC planning department and other departments in respect to housing needs, traffic implications, general infrastructure and future needs of the area.

The plan as it stands does not include details of the massive amount of additional infrastructure needed. Changes to the infrastructure of this magnitude which would necessarily accompany a 30% increase in homes in Knebworth, would significantly change Knebworth's character for the worse. Sixty five more homes have already been built or granted planning permission since the census in 2011 when there were 2002 dwellings in the parish.

Irrespective of the Council's destruction of the greenbelt, they would also be acting against their own 2006 study which stated that "Knebworth is not suitable for further development as it would risk the sustainability of the village". I do not want to see any destruction of the greenbelt. This gives the Village a rural feel and maintains its individuality. Once you encroach into this greenbelt you set a precedent and start the urban sprawl so Woolmer Green, Knebworth and Stevenage end up as one huge conurbation. Under the National planning policy removing land from the green belt can only be done on a site by site basis in exceptional circumstances. You have not even attempted to state the exceptional circumstances and have gone for a blanket removal of land from the greenbelt, contrary to planning case law and the national planning policy.

There are two Conservation Areas adjacent to the proposed development areas; Stockens Green & Deards End Lane, which NHDC is responsible for maintaining. Allowing dense house building so close to these areas would go against NHDC's own publicly stated policy regarding the sites' importance, which includes a section of Park Lane. Furthermore Core Strategy EN2, Covering Protection and Enhancement of Landscape and Settlement Character, states that Development proposals should demonstrate that their location, scale, design, and materials will protect, conserve and, where possible enhance the setting of, and views from Conservation areas. Therefore building a high density housing estate next to these conservation areas would contravene Core Strategy EN2 by ruining their setting and views.
The Strategic objectives ENV1, ENV2, ENV3 and ENV5 will also be contravened by such a huge scheme in relation to the present size of Knebworth.

Access to the sites, which have limited vision, has to be via one of 4 railway bridges which are pinch points and already cause congestion and accidents. Unless the railway bridges are widened the congestion will get worse.

Deards End Lane and Gypsy Lane are already too heavily used by traffic between Stevenage/Codicote and Welwyn/Stevenage. These roads are too narrow to accommodate 2-way traffic along much of their length. Erosion to the verges, drive entrances and the edge of the carriageway testify to this. Many of the entrances to these properties are blind making it difficult for residents to exit as well for cars using the road. The resulting increase in traffic on these roads would not only lead to further deterioration of these lanes (which are presently not adequately maintained by the Highways Department) but the lack of any pedestrian pathways would undoubtedly lead to increased pedestrian accidents.

Substantial alterations to and widening of Gypsy Lane and Deard's End Lane would be needed to allow two way traffic and a pedestrian footpath. Widening these roads, particularly Deard's End Lane, could only be undertaken by compulsory purchase of parts of many private, wooded front gardens. This would totally destroy the character of this conservation area. This would be totally unacceptable. The proposed developments would require new access points to be arranged off the A1M and the B197 south and north of Knebworth and/or the A602, to provide a bypass for Knebworth and for access to the developments west of Deards End Lane and Gypsy Lane. This needs to be completed before any development can begin.

Some of the low lying houses in Orchard Way and Broom Grove are already subject to flooding after heavy rain from excess run off from the fields to the west. Covering those fields (052) with concrete would only make matters worse. No details are given of what type of Sustainable drainage systems would be needed for preventing flooding of parts of Knebworth. It would certainly have to be a large system such as a flood run-off storage reservoir near the middle of the new development where the ground slopes down, to control the flooding of parts of Knebworth including Orchard Way and Broom Grove.

The additional infrastructure and alterations needed to cope with over a 30% increase in the resident population includes extra car parks, expansion of Knebworth Station car park and ticket office, staff and opening times, a new school, library, a new larger village hall, a new doctors surgery with adequate free parking outside. Building houses on the Chas Lowe Site is really inappropriate as this site will be needed for a new doctor's surgery, as well as either a new library or larger village hall.

At present the plan contravenes Strategic objective ECON8 which requires all development to be supported by the necessary provision of improvements to infrastructure, services and facilities. It also contravenes SOC4 which enables rural communities to plan to meet their own local needs, especially through neighbourhood planning.

Many of the objections outlined above have been made to you by many people since early 2015 yet you appear to have ignored them. It is crystal clear that the proposed developments contravene many of your strategic objectives, as well as being out of all proportion to the size of the village and will create major congestion problems. You have also failed to explain how you have calculated the number of new houses needed in this area.

Now that we are leaving the EU the population growth should slow down and as a consequence your proposed developments, whatever way you have calculated them, should now be significantly reduced and delayed. To conform to SOC4 you need to be able to answer the concerns and objections you have received and provide detailed answers to accord with the provisions of ECON 8. Whilst you believe the developers will sort out all these issues raised, you need to be able to justify the housing need, answer concerns of residents over infrastructure etc. or go back to the drawing board.

For the above reasons your proposed developments should not go ahead as they are presently drafted as they are clearly impracticable.

My concerns about the plan:

663 dwellings added to an existing housing stock of about 2,300 is far to great without extensive development of the infrastructure not covered by this plan.

ROADS:
600+ houses is likely to add 1200+ cars.
- There are no plans to provide additional access roads to the main B197 running through the village.
- There are no plans to expand or make changes to existing roads and junctions.
- The 2 railway bridges are narrow and are offset to the road so 2 cars cannot easily pass under these bridges so they are not safely able to support additional traffic
- The 2 railway bridges have narrow pedestrian paths and would be a danger to pedestrians if more traffic tried to pass as they go under the bridges
- The B197 is already used as a bypass for the A!M during rush hours causing extensive congestion in the high street. The high street needs a traffic calming scheme to deter those using the village as an alternative route to the A1M. For example, priority arrows and dog leg sections so only one way traffic passes through the high street at one time. This would also allow bumper to kerb parking so creating more parking to support local businesses. The Lowe's site should be redeveloped to add to and support local use of the high street facilities with additional parking, retail outlets and the new doctors surgery.

WATER, SEWAGE, ELECTRIC AND GAS
These services were installed when the village was first developed with the coming of the railway through the area. Minimal work has been done to cope with the continued expansion of the village since this time.
- There are no plans to develop these services to support the addition of 600+ houses that may require new/additional supplies being brought in to the village from surrounding areas.

As a resident of Knebworth who commutes daily to Stevenage I would like to comment on the local plan currently out for consultation. Overall there are many good goals recommended but these appear to have been largely ignored and development positioned haphazardly around and arguments for the developments then dreamt up.
The plan mentions high recent migration (2.70), whilst this has historically been true and may well continue in the short term the plan is already out of date by not accounting for BREXIT. BREXIT will, inevitably decrease the numbers of households that should be considered as needed POST BREXIT. Whatever the outcome of BREXIT negotiations the influence migration had on the vote will focus the government of whatever colour it may be into restricting this flow. It is not clear how the numbers should be adjusted to account for this or whether this is allowed until directive from central government is received, however, this is a material change in National policy and should now be accounted for.
The plan is considering an increase of approximately 24000*100/131696 % or 18% ish in housing. For Knebworth the plan is considering an increase of 31%. This is not fair nor is it justified anywhere in the plan. In addition the development in Knebworth contravenes para 1.7 (that green belt utilisation should be avoided except in exceptional circumstances.)
The plan positively points out a desire to restrict commuting (paras 4.22 & 4.26). This would if implemented reduce the overall increase in greenhouse gas emissions (para 2.81 states the plan fails to reduce greenhouse emissions and a recent court case has shown this is not acceptable at national level so is unlikely to be acceptable at local level either.) The plan claims to positively bias housing development to the areas earmarked for increased employment to reduce travel (4.22), but in practice has ignored this policy for Knebworth which been earmarked for a reduction in employment (KB3) and so should by this measure expect to attract less than the average housing increase.
The rail services to Knebworth station are continually threatened (and frequently have no space for Knebworth station users at peak times) with changes proposed so as to improve services to larger stations such as Stevenage and Hitchin/Letchworth. If the policy is to promote rail commuting (the plan is not clear on this) then extra housing for rail commuters should thus be in Steveange/Letchworth and Hitchin but not Knebworth or Woolmer Green to avoid road commuting between settlements. As a worker in Gunnels wood road in Stevenage I am aware that a development to the West of Stevenage would be partially within walking distance of that station and if built with cycle facilities to merge with the existing facilities in Stevenage could provide a 100% safe off road cycling route and so for rail or work commuting could be a very Green development. This is ignored in the plan despite sustainable transport being one of its goals. Also as regards Knebworth the access bridge to Knebworth station is dangerously narrow for both road and pedestrian use so developments to the East of the station (KB3 & KB4) cannot be considered suitable for rail commuting.
It is noted that the A1M provides strong North/South links but that other roads also suffer as use as cut throughs (para 2.75). As I commute daily by car from Knebworth to Stevenage I notice that the predominant traffic flow is South in the morning and North in the evening whereas if the road were simply used by local residents and people working along the B197 corridor the traffic flow would be the other way around at this northern end of the road. Hence this road suffers from being used by significant traffic in preference to the purpose built North/south flow A1M. The plan does not address this issue, although if traffic were slowed it would discourage commuting and make it safer for the existing local traffic load and less noisy to local residents so improving their environment (para 2.66 bullet 4).
Referring to para 2.83 much travel between Knebworth and Stevenage (required for jobs & shops to even greater extent if plan implemented) could be undertaken by bicycle but currently the B197 hill down from Knebworth to Stevenage is a no go zone for all but the most confident cyclist as the road markings force motorists to the edge of the road where the cyclist would be, and for going down the hill a second up lane prevents motorist from having room to pass cyclists. To remove cyclists from the motorists' path cyclists are permitted to take the slower and less safe footpath which is strewn with debris, overgrown and insufficiently wide to safely pass a pedestrian. I have noted over the past month that on nine out of ten mornings as I commuted into Stevenage if I had cycled I would have been in conflict with pedestrians if I had used the footpaths. Commuters (whether motorist or cyclist, all are human) want to take the fastest route to where they are going and to be offered an alternative that takes you out of the way and/or delays you is not an alternative but a means of removing the inconvenient few cyclists that persist and promoting the remaining mode of transport (in this case the motorist). This road is adequately wide to have a proper cycle path installed all the way from the centre of Knebworth to the Stevenage Cycle path network. All that has to be done is remove the "up" overtaking lane and central reservations and replace with a speed limit and mini roundabouts to facilitate effective safe access to the roads currently served by chicken zones in the central area of the road. These roundabouts would also permit access to the cycle path and help the motorist comply with existing speed limits. Whilst this would slow the traffic the main pinch point is the Tesco traffic lights and Roebuck junction in Stevenage so it will not in fact reduce the road capacity if the A1M had to be closed, the traffic would merely flow at a more uniform rate, rather like the speed restrictions imposed on motorways when they are busy. The existing traffic causes daily problems, rather than increase these problems with further developments the plan could help address these issues with this example of green infrastructure (para 2.51) to help the plans carbon footprint and reduce future road maintenance bills. Such schemes do not require extra development to make them worthwhile and could also be implemented elsewhere, I am sure, but do not appear to have been considered.
Other laudable goals are to protect open spaces (ENV3), support rural diversification (Econ 6), minimise need to travel (ECON 7) and re-use previously developed land whilst offering opportunities for new infrastructure (3.3). The development planned in Knebworth contradicts all these goals, the quantity of extra homes in Knebworth is so high that the nature of the entire village would be changed to a commuting monoculture, more travel would be enforced on all residents by removal of retail facilities (kb3, also contradicts 2.74), open spaces removed and partial merging with Stevenage (kb4, also ignores 4.55) and on entirely green belt or existing currently used land. On top of that no infrastructure developments are planned other than rebuilding existing facilities (13.200) that already cannot cope with existing demand. The suggestion that a new secondary school may be built here implies the planners have realised the extent to which they have adversely altered the environment but given that such a small school would be able to offer very little choice the viability from an educational view point is very dubious and restraints on budgets would almost certainly prevent any such development in the long term.
The plan totally fails as regards Knebworth by making it less self-sustaining, less green( 2.81), less diverse (econ 6), with less facilities(Kb3 and 2.74), more travelling and more polluting (Econ 7) less healthy (2.77), less open spaces (2.80) .
Development in Knebworth was expected to contribute to the goals of a strategic plan for the district as a whole but what is proposed does not fit in with the goals. Moreover it has missed the opportunity to provide housing to match the employment opportunities locally expected in Hitchin, Letchworth, Stevenage and especially in the North of the district where average only increases are planned for the huge employment prospects envisaged coming from Cambridge and Peterborough. As for the environmental effect of the overall plan, the Knebworth developments are entirely negative to the plan and actually promote travel, one of the key items required to be reduced to address climate change, one of the goals of the plan (1.7). The plan actually largely ignores such issues which may be better addressed by a new town where a complete Green infrastructure could be implemented. An alternative would be to ensure that new housing developments are linked to their intended social and employment target zones by pedestrian, cycle, and public transport means to the detriment of the more environmentally damaging forms of transport, not merely fitted in alongside if space is available. This plan is basically still promoting increased traffic flow and relegating "greener" transportation to leisure activities, which may go a small way to addressing health issues but actually also generates more motorised traffic as the users of such facilities try to get to the restricted areas where such facilities exist but are unable to use them for daily social or work activities.

The plan does not disclose any strategy for sustainability of Knebworth. Knebworth's infrastructure is already under enormous pressure and the plan does not set out any way in which this strain is to be elevated. The roads are congested, the station is over-used and it is near impossible to obtain a doctor's appointment. None of this has been addressed.

In addition, there is no indication of any new job creation in the village meaning that the already heavily used roads and railways will be further strained by more commuters.

Further, drainage issues do not seem to have been considered. There is a real risk of surface water flooding.

The amount of proposed new housing is not justified when Stevenage West land is reserved and the extra impact of Woolmer Green plans are not considered.

There is a real danger that Knebworth's identity as a separate village will be jeopardised. The plans are contrary to Government policy.

The proposed sites will destroy the open countryside which is used by locals for recreation and is a valuable asset to the community, not to mention its addition to the attraction of Knebworth. The whole character of the village will be changed and destroyed.

The proposed site on Gypsy Lane, will be near to the A1. We hear the A1 where we live. I cannot imagine anyone wanting to live any closer to it than we do. The noise and pollution would be unbearable. This location is entirely unsuitable for a primary school for the same reasons.

There are real concerns about access to the proposed site off Gypsy Lane. The narrow lanes and narrow railway bridge make this site unsuitable for development.

The development is likely to impact adversely on wildlife and will damage the character of Stockens Green Conservation Area.

This message is to put on record my very deep concerns about the proposed plans to increase the housing in Knebworth..

The lack of parking in the village has forced commuters to park densely in this narrow road up to and beyond the entry to my house such that it is difficult to exit my drive safely.
Parking and severe congestion is a well known and major problem in and around the village centre and all the surrounding roads. The Proposed Plan CAN ONLY MAKE THE PRESENT SITUATION EVEN MORE SEVERE AND IS UNSUSTAINABLE.

I wish to respond to the proposals for this area.

Firstly the proposed number of houses is excessive compared to the current size of the village. It would increase it by almost one third. There are also plans for substantial numbers of houses in Stevenage and Woolmer Green which will impact the area severely.

Road and rail services are already under considerable strain and there do not appear to be any plans to increase provision. Other services are also stretched and /or inadequate. Drainage and sewage disposal are already suffering capacity problems.

Nor are there any plans to provide local jobs or provided more shops and facilities in the village. Presumably it is thought that the newcomers will all commute to London or other towns adding to current congestion and traffic problems. Pollution will also increase.

It will result in the loss of green belt around Knebworth and lead to the coalescence of settlements against Government policy. We will also lose access to the countryside and wildlife will be badly affected. Conservation areas will be impacted and agricultural land will be lost.

For all these reasons I am against the proposals in the Local Plan.

I have submitted online representations to Sites KB1, KB2, KB3 and KB4. These are my comments on paras 13.183-13.202.
663 new dwellings are proposed in Knebworth in the period to 2031. An increase of nearly 1/3. I cannot see how these can be accommodated without putting the following under intolerable stress:
The road system
The station and rail system
The Doctors' surgery (even if it moves to the library site)

There is no cohesive plan for the creation of employment for the extra people - in fact one of the major employers, Chas. Lowe, will be redeveloped as housing. The town - as Knebworth will become - will change from being a community to a dormitory town - with a population of tired, frustrated commuters who barely see the daylight in the winter months.

Previous Local Plans have concluded that Knebworth is not suitable for development because of infrastructure problems, not only the transport network, but the sewage, and the surface flooding. What has changed?

The proposals to remove Green Belt are contrary to NPPF Para 14 footnote 9. The two village Conservation areas, around Stockens Green and Deards End Lane, will also be put at risk by the proposed developments.

It beggars belief, but my understanding is that none of the proposed developments include the affordable housing so desperately needed.

My response in respect of the above is as follows.

Sites 52 and 53 are unacceptable due to the very limited access under the railway bridges at Station Road and Gun Road where the carriageways are of inadequate width to accommodate passing vans, never mind lorries and both suffer from single narrow footpaths of insufficient width for two persons to pass each without one stepping into the carriageway with the dangers that can encounter.

Site 57 is totally unsuitable due to the inadequacy of Swangleys Lane and the school with its associated parking by parents situated at the junction with London Road.

To accommodate sites 52 and 53 the bridges at both Station Road and Gun Road would need their carriageways significantly widened to accommodate the extra road traffic generated by the additional proposed development.

Any development of the magnitude proposed should be accommodated West of the A1M at Stevenage as was proposed at an earlier date, albeit this may not be within the administrative area of NHDC.

New development needs to be undertaken properly by the formation of new towns and not on the cheap by adjoining it to existing settlements where the infrastructure to accommodate it is inadequate.

I am writing to express my concern as to the proposed building of 663 houses in Knebworth.

Knebworth is a village surrounded by Green Belt land, and country lanes and narrow bridges. This land acts as a buffer and prevents the village becoming one long sprawl with Stevenage to the north and Woolmer Green to the south. Where this land is arable land then it should be retained for the growing of food.

Knebworth is already bursting at the seams re-utilities, doctors' surgery, school and use of railway . A huge issue is the traffic coming through the village on the B197 and when the local A1M is blocked .... a regular occurrence. The narrow lanes surrounding the village and the proposed building sites are constantly used as rat-runs to beat the traffic problem. It is well known that commuter parking is a huge problem with people driving in from Stevenage and the villages wanting to park before using the train station. NHDC know of the problems with parking and through traffic but have not been able to find a solution .

Site KB2 is not suitable for housing, let alone a new school. The site is very close to the A1M with its pollution , and also the land regularly floods into the nearby estate with water flowing off the motorway.

I hope that those making decisions about the proposed new houses first come to Knebworth and see for themselves just how inappropriate the plans are.

Overall strategy:
The overall strategy is not clear. In fact, there is not an overall strategy and as such means that the plan is not effective. The fact that there is no strategy is apparent in the lack of connections between housing, cumulative development and infrastructure needed to support growth sustainably. Therefore, the plan is not sound.
Amount of housing:
The amount of new housing (663 dwellings) would increase the village size by 31%. This is an increase of approximately 200 homes in this Plan to 2 years ago. None of the issues highlighted then have been addressed, so how can the village now support and additional 200 homes to 2 years ago? Please note Knebworth is a village, even though it is referred to as a town in the Plan.
Plan for over 500 homes should have a specific plan with developer obligations. Because of the separate sites, this obligation has been overlooked at bets, or deliberately manipulated at worse (by calling each site separate in its own right, rather than all part of the Knebworth site). There is no provision for jobs creation in the Plan as a whole and therefore no consideration for the local economy.
Planning has been granted for the Odyssey site to the north of Knebworth for approx. 70-100 homes. This hasn't been taken into account when determining amount of housing for Knebworth. These houses are being termed 'windfall gains'. A clear strategy should take these into account.
Furthermore, Stevenage West land has already been reserved for 3,100 homes. This would be better able to provide facilities and services.
There is no joined up thinking with adjacent parishes. Plans for Woolmer Green of 150 homes (to the north of Woolmer Green) have not been taken into account. If all the proposals go ahead then Knebworth and Woolmer Green will merge and Stevenage and Knebworth would be practically joined up. The town and villages will all merge into one.
The site KB4 has not previously undergone any consultation. This is against policy and verging on illegal.
Chas Lowe site: Again, as there is no proposal for any commercial use it is evidence of a lack of strategy for Knebworth. The village centre will be changed and this will have an impact. The facilities of Knebworth are designated as a village centre in the retail hierarchy under policy SP4. Therefore, any development of the village centre needs to take this into account. At a bare minimum, some mixed use should be proposed.
Transport:
It was raised in the previous consultation in 2014 that the existence of the railway line poses huge challenges regarding transport/traffic through the village. These challenges have not been addressed in this plan; in fact, the Plan says (13.195) that there are no mitigation requirements regarding transport. In fact, the Highways Agency has raised this issue previously. The problem with the bridges has been ignored. The two railway bridges at either end of the village are already dangerous due to the current volume of traffic, narrow roads, corners, and narrow pavements. An increase in volume of traffic and pedestrians will make this increasingly dangerous. There have already been many near misses. These two routes are used extensively by small children going to and from school, in the morning rush hour. An increase of 31% of this scale can only add to the problems.
The high street is also a known pinch point; it current takes over 35 minutes to reach junction 6 of the A1 in rush hour, which is only 2 miles away. Increased traffic will only exacerbate this).
Deards End Lane is already dangerous, and it can't be widened. It is unsuitable for heavy traffic and increased traffic will make it more dangerous and over-crowded.
In the Plan (13.192) it states that much of the traffic in the mornings is caused by secondary school pupils going to school in the car. This is simply not true. Virtually ALL secondary school pupils use the trains (to Hitchin and Hatfield) and the school provided buses (to Stevenage, Welwyn Garden City, Hatfield, Hertford, Ware), and public buses. Therefore, the idea that possible secondary school provision could ease the traffic volume is simply inaccurate.
Regarding site KB4, there is an obvious lack of capacity on Watton Road and Swangley's Lane.

Schools:
Primary:
* A second primary school on site KB2 is not well considered. This would be adjacent to the A1 and as such noise and air pollution will be significant. Children and teachers cannot learn and teach in this environment. In December 2014 the Environmental Audit Committee issued a report stating that: 'A ban on building schools, hospitals, and care homes near air pollution hotspots must be introduced to help cut thousands of deaths connected to the 'invisible killer' of traffic fumes.'
* A second primary school will change the village feel of Knebworth to more of a town, or urban sprawl. It will increase pressure on the roads under on the railway bridges because more people would be crossing the village each morning, in both directions, with young children. I would be naïve to assume that parents would automatically chose the primary school nearest to them, or on their side of the village
* Finally, regarding a new primary school, it will create a 'divide' in the village. One school will be 'better' than the other, and therefore a social dividend will emerge. This would not be healthy for the community feel of Knebworth.
Secondary:
In the Plan (13.192) it states that much of the traffic in the mornings is caused by secondary school pupils going to school in the car. This is simply not true. Virtually ALL secondary school pupils use the trains (to Hitchin and Hatfield) and the school provided buses (to Stevenage, Welwyn Garden City, Hatfield, Hertford, Ware), and public buses. Therefore, the idea that possible secondary school provision could ease the traffic volume is simply inaccurate.
13.193 mentions an 'all-through' school. It uses the term 'possibly' and 'provides the opportunity to look at alternative approaches' .This is certainly nothing definitive. It does not seem likely that a secondary school would be built; in fact, there is not actually a shortage of secondary school places in Stevenage and so there would be no reason to provide a secondary school.

I have been considering your Local Plan, particularly in respect of the west side of Knebworth, and consider it ill-conceived;

Irrespective of your Council's proposed destruction of the greenbelt, you would also be acting against your own 2006 study which stated that "Knebworth is not suitable for further development as it would risk the sustainability of the village". Nothing has changed since then so it seems you make sound-bites to suit yourselves!

There are two Conservation Areas adjacent to the proposed development areas; Stockens Green & Deards End Lane, which NHDC is responsible for maintaining. Allowing dense house building so close to these areas would go against NHDC's own publicly stated policy regarding the sites' importance, which includes a section of Park Lane. Furthermore Core Strategy EN2 Covering Protection and Enhancement of Landscape and Settlement Character states that development proposals should demonstrate that their location, scale, design, and materials will protect, conserve and, where possible enhance: The setting of, and views from Conservation areas. Therefore building a high density housing estate next to these conservation areas would contravene Core Strategy EN2 by ruining their setting and views. The Strategic objectives ENV1, ENV2, ENV3 and ENV5 will also be contravened by such a huge scheme in relation to the present size of Knebworth.

Access to these two sites, has to be via one of 4 narrow railway bridges, 3 of which have limited vision, which are pinch points and already cause congestion and accidents. Unless the railway bridges are widened the congestion will get worse. However, widening these bridges and straightening the approaches is not a viable option, especially the one at Deards End Lane. The best of the 4 bridges is the one at Woolmer Green but the road to the west of it is a single track along Wych Elm Lane between open fields

Deards End Lane and Gypsy Lane are already too heavily used by traffic between Stevenage & A1(M), and Codicote, Whitwell, Wheathampstead, Harpenden, Luton and Welwyn. These roads are too narrow to accommodate two way traffic along much of their length. Already, erosion to the verges, drive entrances and the edge of the carriageway testify to this with many potholes. Many of the entrances to these properties are blind making it difficult for residents to exit as well for cars using the road. The resulting increase in traffic on these roads would not only lead to further deterioration of these lanes, and the fact they lack any pedestrian pathways would undoubtedly lead to increased pedestrian accidents. This danger to pedestrians through lack of pathways and flooding is a constant concern as vehicles have been monitored along Deards End Lane at over 40 miles per hour. Pedestrian accidents have been reported to the Police and the Council but requests to introduce a 20 miles per hour speed limit have either been flatly refused "until someone is killed", or been pushed from pillar to post - each department denying it is their job.

Widening these roads, particularly Deard's End Lane, would totally destroy the character of this conservation area and would be totally unacceptable. The proposed developments would require new access points to be arranged off the B197 and the A1(M) B197 south and north of Knebworth to provide a bypass for Knebworth and for access to the developments west of Deards End Lane and Gypsy Lane. This would be essential before any development could possibly begin.

You have mentioned in your plan regarding Knebworth "the High Street is a known pinch point, particularly when delays or incidents on the A1(M) result in the B197 being used as an alternate route between Welwyn Garden City and Stevenage." With just a modicum of joined up thinking for the future, this problem can be partially relieved by bypassing Knebworth with a relief road.

I continue to give details below, not just about your justification, or lack of, for the density of your proposed housing but also the need for such housing.
Some of the low lying houses in Orchard Way and Broom Grove are already subject to flooding after heavy rain from excess run off from the fields to the west. Flooding is also a problem in the High Street and Pondcroft Road where sandbags have to be used to block doorways during heavy rain. Some of the existing drains are blocked by stones and gravel. Covering those fields (052) with concrete would only make matters worse. No details are given of what type of sustainable drainage systems would be needed for preventing flooding of parts of Knebworth are included. It would certainly have to be a large system such as a flood run-off storage reservoir near the middle of the new development where the ground slopes down, to control the flooding of parts of Knebworth including Orchard Way and Broom Grove. Flooding occurs at the junction of Deards End Lane with Park Lane EVERY time it rains as the controlling body either does not have the funds or the inclination to do anything about it (see attached pictures) and this has been the case for many years. The surface drain at that point is currently 4 inches deep in sludge over the top of the drain hole and plants are now growing there. What hope is there for effective major flood defences elsewhere in the village, particularly if developers are going to asked to pay for it?

The additional infrastructure and alterations needed to cope with your proposed 33% increase in the resident population would have to include; extra car parks, expansion of Knebworth Station car park and ticket office staff and opening times, a new school, library, a new larger village hall, a new bigger doctors' surgery with adequate free parking outside. Building houses on the Chas Lowe site is really inappropriate as this is the most appropriate location for a new doctor's surgery, and new library rather than the restrictive site currently proposed in St Martin's Lane. Very short sighted! The Chase Lowe site should also be fronted by retails units to maintain the sustainability of the village centre.

At present the plan contravenes Strategic objective ECON8 which requires all development to be supported by the necessary provision of improvements to infrastructure, services and facilities. It also contravenes SOC4 which enables rural communities to plan to meet their own local needs, especially through neighbourhood planning.

Many of the objections outlined above have been made to you by many people since early 2015 yet you appear to have ignored them. It is crystal clear that the proposed developments contravene many of your strategic objectives, as well as being out of all proportion to the size of the village and will create major congestion problems. You have also failed to explain how you have calculated the number of new houses needed in this area.

To conform to SOC4 you need to be able to answer the concerns and objections you have received and provide detailed answers to accord with the provisions of ECON 8. Whilst you believe the developers will sort out all these issues raised, you need to be able to justify the housing need, answer concerns of residents over infrastructure etc. or go back to the drawing board.

For the above reasons your proposed developments should not go ahead as they are presently drafted.

I enclose my comments on the North Herts Plan (for Knebworth )-Paragraphs (13.183-13.202 of the local plan).

I object to the plans for Knebworth as outlined in the Local plan for reasons of Soundness.

The Green Belt policy serves 5 purposes
* to check the unrestricted sprawl of large built-up areas;
* to prevent neighbouring towns merging into one another;
* to assist in safeguarding the countryside from encroachment;
* to preserve the setting and special character of historic towns; and
* to assist in urban regeneration, by encouraging the recycling of derelict and other urban land

These plans recommendation do neither of the above.

A local planning authority should regard the construction of new buildings as inappropriate in Green Belt. Exceptions to this are:
* buildings for agriculture and forestry;
* provision of appropriate facilities for outdoor sport, outdoor recreation and for cemeteries, as long as it preserves the openness of the Green Belt and does not conflict with the purposes of including land within it;
* the extension or alteration of a building provided that it does not result in disproportionate additions over and above the size of the original building;
* the replacement of a building, provided the new building is in the same use and not materially larger than the one it replaces;
* limited infilling in villages, and limited affordable housing for local community needs under policies set out in the Local Plan; or
* limited infilling or the partial or complete redevelopment of previously developed sites (brownfield land), whether redundant or in continuing use (excluding temporary buildings), which would not have a greater impact on the openness of the Green Belt and the purpose of including land within it than the existing development.

And falls foul of the above exceptions

I also include General and Site(KB1-4) related observations and comments .

General: Knebworth is a natural conurbation existing between hills to the west, north and south East. All traffic radiates through the centre of Knebworth either down the north south conduit (B197) or the east west conduit via Watton road/Station road. At peak times 7-9 am, 4-6.30 pm these roads are very busy and congested leading to tailbacks on all roads. There is not enough provision or evidence of provision for infrastructure to cope with the increase in traffic caused by 600 new homes and not sure how any improvement can be achieved. It will be grid lock.
General :The plan talks about an inadequate car parking management policy in the high street. Car parking is allowed in the High street to make ease of access to shops but also to actually slow the traffic down. We don't want traffic hurtling through the village.
General: There is no provision in the plans for the increased rail usage and therefore additional parking capability required in Knebworth. Currently all roads local to the Station are rammed with commuter cars.This will only increase with the additional 600 homes in , the 150 in Woolmer Green and the 3100 west of Stevenage. Currently a lot of Stevenage people drive to the village in the morning so that they don't have to pay car parking at Stevenage station.
General: Knebworth is a large village. The proposed development will turn Knebworth into a small town but without the facilities of a small town. The village will lose its openness and valuable agricultural land will be lost.
General: The doctors surgery struggles to cope with local demand. It currently can take 2 weeks just to get regular appointment. This will be exasperated by the increase in the number of people. The latest planning application from the Surgery has been rejected by North Herts.
General: The proposed schooling provision has not been syndicated or agreed by County. The figures don't lie, 600 homes means 600 kids which means 20 classes of 30 ( Year 1-13) which means you need more than 1 form entry for the new primary school.
General: It is not clear how the through school site on KB4 is going to operate. Will it be in addition to the existing provision or replace the existing provision. What traffic increase has been taken into consideration in the infrastructure to cope with this new school or the traffic flow that will result. Particularly increased flow from Stevenage as a result.
General: Current educational policy states that there is a nearest to school policy when assessing prioritisation. It will be ironic that Bragbury end will be closer to the new through school on KB4 than the west of Knebworth , thus precluding those children from the west of Knebworth from places at this school.
General: There is no provision for additional local employment in the plan
General: There is no provision for additional sporting facilities in the plan.
General: There is no evidence of land being set aside within these development locations for leisure usage.
General: There are no hard facts on the amount of low cost housing that will be set aside.
General: There is no mitigation in the plan for the number of houses being built at nearby Woolmer Green(150) or the those being built West of Stevenage (3100).
General: There has been no consultation with the the village with regard to educational provision. Did the residents ask for an 'all through' school. What process had been followed to get that conclusion and where is the transparency to that process.
General: The plan cannot be sustained without major investment in infrastructure. I cannot see any evidence in the wider county budget for this.
General: What benefits does this plan bring to Knebworth-that has never been articulated. Where are the local needs reflected in the plan.
General: No Resource planning has been given to the additional levels of Policing and other essential services that these developments will bring. Will this plan plus others in adjoining towns and villages take this beyond was has currently be budgeted for of forecasted for.
General: What studies and modelling has been used to predict increase in road/rail usage and where is the transparency to those artefacts.
General: This plan removes huge swathes of green belt to the west and east of Knebworth. What other options have been considered and where is the transparency to that process.

KB3:The Chas Lowe site is a valuable employer in the village (in fact the largest employer).This employment is not being replaced.
KB3:This has badged as a Retail only site. This is ridiculous ..at very least it should be mixed. Thus providing residents with additional shop or even a location for the surgery. The unit on the east side of the high street is currently a small yard between 2 commercial units and the plan is showing residential development-this is ludicrous. Where are these new residents supposed to park a car ?

KB4:The due diligence on this site has not been undertaken. This option game late to the table and has not been given the same level of scrutiny as the other sites and equally not the same level of scrutiny by the community.
KB4: the proximity of the development to Stevenage increases coalescence between and urban area and a small village. This must be avoided at all costs as Knebworth will lose its identity.
KB4:Any development here will reduces the open landscape currently enjoyed by the village community
KB4: Any infrastructure that causes traffic to ingress/egress through Oakfields road/avenue into KB4 and out into Watton road will turn a quiet residential area into a rat run and a dangerous road for all users.
KB4:The land here is constantly farmed, with multiple crops rotations per year-This will be a valuable asset lost. A wide variety of birds use this area as nesting site- both local and migrational.
KB4:Swangles lane is a nightmare at school times, with one lane traffic movement only at peak times. The additional homes in this area will increase this issue.
KB4:Watton Road is regularly flooded both at the junction with the railway bridge near Bragbury end and halfway down Watton Road close to the junction with old lane. There have been many accidents along this road , with many cars ending up in adjacent fields. This development will increase this issue as run off will be exasperated.
KB4:This Is NO footpath provision along the busy Watton road beyond Bell close.
KB4: Damage to the look and feel of the Picton built houses and road vista in Oakfields Avenue/Road .
KB4:Any entrance to site KB4 from the junction of Oakfields ave/road will mean compulsory purchase of land from properties adjacent to that site. It would not be possible to get traffic in and out without doing so.
KB4:I have seen no evidence that suggest that County have agreed to the Schooling proposals.

KB2:Building up close to the A1(M) would seem unwise considering the noise and population from the road. Putting a school here contravenes planning law of not building a school within 150 metres of a major road (A1M). Better off developing existing school site.
KB2:I have seen no evidence that suggest that County have agreed to the Schooling proposals.
KB2:The green belt buffer will be removed by this development thus removing the open nature of this part of Knebworth.
KB2:Orchard Way suffers from flash flooding. This will be exasperated by this new development as water will have even less ways of dispersing.


KB1:The design of the Bridge @ Gypsy Lane and the narrowness of approach to it from both ends will become a major bottleneck because of the extra traffic that needs to go through it. Extra infrastructure needs to be factored into the cost of developing the bridge further to support this site.
KB1:Deards End lane in parts is suitable for single file traffic only. This road will have to be upgraded to support the extra traffic...and will have to involve compulsory purchase of land.
KB1:The closeness of this development close to the A1M raises issues on whether the pollution and noise generated by the A1M would be tolerable. Tests would have to be undertaken to understand emission levels.
KB1:This development will affect the look and feel of the conservation area in Deards end.

Design: Knebworth retains its rural garden village feel because many of the houses have boundaries formed of natural hedges rather than wooden fences .It would seem prudent that if this awful development went ahead that this design feature was enshrined in local covenants within the new development.
Design: Knebworth also benefits from its association with Lutyens , which is reflected in both local housing, the church and the golf club. It would be beneficial for those design concepts to be reflected in any new development.

The following representations are made with respect to the North Hertfordshire Proposed Submission Local Plan (the "Local Plan").

POSITIVELY PREPARED

1. The Local Plan has not been positively prepared in the context of Knebworth (paragraphs 13.183-13.202 of the Local Plan).

2. Knebworth is a village of some 4,500 inhabitants and contains approximately 2,000 dwellings. The Local Plan proposes to build another 663 homes in Knebworth, increasing the number of dwellings by a third. This is an unrealistic aim if proper account is taken of the logistical and environmental constraints to which the parish is subject.

3. The NHDC Infrastructure Delivery Plan of September 2016 sets out the current state of the village:

- Knebworth's railway station had patronage of approximately 600,000 travelers in 2014/15, a 71 per cent. increase on the figure ten years earlier. Commuting from the station is getting increasingly crowded, a problem which will be exacerbated if the proposed revisions to the rail network are implemented in 2018, leading to a reduction in the number of fast trains during the rush hour period
- Knebworth is classified as having very limited capacity for school provision, and has no ability to cope with housing growth
- Knebworth Medical Practice takes on 33 patients per square metre, and is over accommodated by 5,000 patients
- Knebworth Library is small (234 square metres) and requires additional stock, shelving and IT
- Thames Water is of the view that further consideration is needed of Knebworth's sewerage capacity, and that issues with the foul sewer system need reviewing as the village does not have a dedicated surface water system

4. To that I would add the following observations:

- The village's road network is limited both in terms of extent and with regard to the quality and capacity of the thoroughfares themselves
- The lack of adequate parking facilities in the village is a significant cause of congestion, and a source of frustration for local residents. The High Street (B197) is a constant pinch point for traffic, leading to significant tailbacks and traffic jams at peak travel times, with vehicles often unable to travel in opposite directions along the High Street at the same time due to the number of parked cars
- The High Street contains a modest number of enterprises and shops, albeit of some variety. As an illustration of the limited nature of local commercial activity, there is only one eat-in restaurant open in the village in the evenings.
- The village has two Conservation Areas (Deards End and Stockens Green) which would be negatively impacted (in terms of noise, pollution, traffic, outlook etc.) by the nearby construction of hundreds of new dwellings
- The land at Deards End Lane on the west side of the village, a Green Belt site on which development is proposed, is proximate to Knebworth Woods SSSI
- The Local Plan also envisages the creation of 150 new homes in the neighbouring settlement of Woolmer Green. The additional impact of these new homes upon Knebworth has not been considered at all in the Plan.

5. It is clear from the above that there are a number of constraints militating against any meaningful expansion of housing in the village. With regard to the Local Plan's potential impact upon Knebworth, it is particularly difficult to justify a proposed increase in housing of such a magnitude when land is reserved at Stevenage West for some 3,100 homes.

6. However, an examination of the Local Plan reveals a failure on the part of NHDC to take any of the above into account in a meaningful way. The NPPF lists three dimensions to sustainable development, none of which are addressed by the proposals for Knebworth:
An economic role - the Plan fails to meet the requirement of "identifying and coordinating development requirements, including the provision of infrastructure". No explanation is given as to how the roads around the parish could reasonably be expected to cope with the significant increase in traffic which the proposed development would bring (when it is clear to any local resident that this would be hugely problematic); no explanation is given as to whether and how public services such as medical facilities, library, pharmacies would be improved and extended; no ideas are put forward to address the impact on local parking facilities, particularly around the railway station.

A social role - implementation of the Local Plan in Knebworth could not conceivably be regarded as "creating a high quality built environment, with accessible local services that reflect the community's needs and support its health, social and cultural well-being". The proposals amount to nothing more than the unceremonious dumping of over 600 new homes and a primary school on the borders of a village which is already struggling with its existing infrastructure. The idea that this should be done through the removal of land from the Green Belt surrounding the village (as to which see further below) merely adds insult to injury.

An environmental role - the Plan could in no way be regarded as "contributing to, protecting and enhancing our natural, built and historic environment". It would involve the elimination of large quantities of the Green Belt surrounding the village; the building of hundreds of houses on a site adjacent to a Site of Special Scientific Interest and to a Conservation Area; a likely negative impact on local wildlife sites; and the construction of dwellings bordering on the A1(M) with its concomitant pollution and noise.

7. In the context of Site KB1 (land at Deards End Lane), I would in particular draw attention to the complete absence of suitable road networking to support housing development on this land. Occupants of this site travelling through the village either to Stevenage or the A1 would need to travel down Park Lane, under the railway bridge which struggles to accommodate two cars travelling in opposite directions, and on to the High Street, which already suffers significantly from congestion; or travel via Deards End Lane itself, which is a narrow unlit lane with no road markings and no street lighting, is too narrow in three or four places to allow cars to pass one another, and has at one end a Scheduled Ancient Monument in the form of a railway bridge. The failure of the Plan to address this fundamental problem, and indeed the problem of traffic around Knebworth more generally, at a preliminary stage is both bewildering and damning.

JUSTIFIED
Housing Requirement
1. The methodology employed in calculating the Housing Requirement for North Hertfordshire is fundamentally flawed (paragraph 4.86 of the Plan).

2. The Stevenage and North Hertfordshire SHMA Update 2015, jointly commissioned by North Hertfordshire District Council and Stevenage Borough Council, sets out in Chapter 2 the basis upon which the Objectively Assessed Need ("OAN") should be established; and it is from the OAN that the Housing Requirement is eventually derived. As the SHMA Update noted, paragraph 15 of the Planning Practice Guidance published in March 2014 places emphasis on the role of CLG Household Projections as the appropriate starting point in determining the OAN.

3. The 2012-2037 Household Projections produced by CLG, published on 27 February 2015, represent the most up-to-date estimate of future growth. These projections suggest that household numbers across Stevenage and North Hertfordshire will increase by 21,280 over the 20-year period 2011-31, an average of 1,064 per year. The SHMA Update of 2015, however, took the view that growth of 19,213 households over the period, equating to an average figure of 960 households per year, was a more appropriate figure based on 10-year migration trends. That figure of 19,213 households was then adjusted to take into account vacancy and second home rates (i.e. dwellings rather than households), suppressed household formation rates and market signals - see Figure 40 in paragraph 3.88 of the SHMA Update 2015. This resulted in a Full Objectively Assessed Need for Housing for the period 2011-31 of 21,685 dwellings.

4. A further update report, published in August 2016, adjusted the Full Objectively Assessed Need for Housing for the period 2011-31 down to 21,400 dwellings on the basis of more recent migration trends. This figure comprised 13,800 dwellings for North Hertfordshire and 7,600 dwellings for Stevenage.

5. There remains flexibility to allow the CLG Household Projections to be applied in the most rational and sensible fashion when calculating the OAN. Paragraph 017 of the "Housing and economic development needs assessments" section of the Planning Practice Guidance which sits alongside the National Planning Policy Framework states that:

"The household projections produced by the Department for Communities and Local Government are statistically robust and are based on nationally consistent assumptions. However, plan makers may consider sensitivity testing, specific to their local circumstances, based on alternative assumptions in relation to the underlying demographic projections and household formation rates. Account should also be taken of the most recent demographic evidence including the latest Office of National Statistics population estimates.
Any local changes would need to be clearly explained and justified on the basis of established sources of robust evidence.
Issues will vary across areas but might include:
* migration levels that may be affected by changes in employment growth or a one off event such as a large employer moving in or out of an area or a large housing development such as an urban extension in the last five years...." (emphasis added)


6. In the case of North Hertfordshire, migration rates over the past fifteen years have been impacted significantly by the Great Ashby development on the outskirts of Stevenage. Over 1,600 dwellings were delivered pursuant to this development between 2001 and 2011 in response to the housing requirements of Stevenage, of which Great Ashby forms part, although a majority of those dwellings actually fall within North Hertfordshire.

7. The significance of Great Ashby was acknowledged in the original North Hertfordshire SHMA from 2013 - paragraph 55 of that report noted that:

"An issue for North Hertfordshire is that over the past 11 years over 1,600 dwellings have been delivered in Great Ashby on the outskirts of Stevenage, or an average of 150 per annum. It can be argued that these dwellings are artificially boosting the number of in-migrants to North Hertfordshire, while fulfilling the role of meeting the needs of Stevenage."

8. The report seeks to make adjustments for long-term migration trends precisely over the period in which the Great Ashby development took place. If Great Ashby is relevant to in-migration levels, in that it artificially boosted them over the relevant timeframe, it will obviously need to be taken into account. The report goes on to show the effect upon the migration-led figures if the Great Ashby effect is removed from the equation - 150 homes per annum for 20 years means 3,000 fewer households. Given that the Full Objectively Assessed Need for Housing for North Hertfordshire for the period 2011-31 stands at 13,800 dwellings, an adjustment of this magnitude would be significant.

9. However, the flexibility granted under the Planning Practice Guidance to make allowance for the development at Great Ashby was not utilised, and the OAN was not adjusted to take account of Great Ashby and its effect upon in-migration figures. The original North Hertfordshire SHMA of 2013 dismissed the need to make an adjustment on the basis that "the number of migrants moving to or from North Hertfordshire is not closely linked to dwelling delivery in the whole of North Hertfordshire or in Great Ashby" (see paragraph 56 of that report). In support of this assertion, the report referred to Figure 8 (on page 15 of the report) which illustrated property sales in North Hertfordshire (including Great Ashby) compared with gross migration trends. The report concluded that Figure 8 displayed no meaningful correlation between in-migration and dwelling delivery rates (and, by implication, no justification for an adjustment under paragraph 17 of the Planning Practice Guidance) on the basis that "since 2008 it is noticeable that the number of in-migrants has not dropped in line with the drop in the number of sales of dwellings or completions since 2007."

10. An examination of Figure 8 shows this conclusion to be erroneous to a very significant degree. Firstly, there is a clear and direct correlation over the life of the graph between in-migration and both total property sales and total property completions, with each of the variables rising and falling in time with one another. Secondly, even if analysis is confined purely to Great Ashby completions versus in-migration, that correlation is still substantially there, with only one exception - an uptick in in-migrants in 2009-10 when Great Ashby completions decreased. However, for no obvious reason the report has taken that one exception as the justification for its conclusion that no correlation can be discerned.

11. Extrapolation of the historical in-migration data without adjustment for the obvious effect which Great Ashby has upon the figures will inevitably lead to a distorted conclusion. For what it is worth, I would note that the most recent ONS migration figures for North Hertfordshire (for the 12 month period to mid-2015) show net in-migration to the area of 425 persons; this compares with an average of 768 persons per annum over the previous ten year period.

12. The lack of meaningful and rational analysis in this section of the SHMA is underscored by the inclusion of completely conjectural statements ("If the dwellings in Great Ashby had not been completed, migrants who have been moving to Great Ashby may have moved to other areas of North Hertfordshire") and assertions which fly in the face of the empirical evidence presented in the report itself ("...a reduction in provision will...see more out-migration from North Herts.").

13. The failure of the original SHMA to take account of the Great Ashby development, a mistake which has fed through into the eventual OAN figure, is a fundamental error with a profound impact upon the eventual 'Policy On' Housing Requirement figure. More broadly, the clear lack of analytical discipline employed in considering the relationship between housing provision and in-migration suggests that any conclusions drawn are largely spurious. In the absence of a reliable and realistic Housing Requirement figure, the validity and credibility of the Local Plan is wholly undermined.

CONSISTENT WITH NATIONAL POLICY
Green Belt
1. The proposal under the Local Plan to remove land from the Green Belt, both from sites around Knebworth and more generally in North Hertfordshire, is not consistent with national policy as set out in the National Planning Policy Framework (NPPF) (paragraph 4.53 of the Plan).

2. Under the terms of the NPPF, "Green Belt boundaries should only be altered in exceptional circumstances, through the preparation or review of the Local Plan." The notion of "exceptional circumstances" unavoidably involves an element of subjectivity, with the Department of Communities and Local Government content to entrust decision-makers with the obligation of reaching sound planning judgements on whether exceptionality exists in the circumstances of an individual case.

3. As a starting point, I would therefore draw attention to NHDC's purported approach to the question of Green Belt development. This is set out in Agenda Item No.6 of the Cabinet Meeting of 24 November 2014, being a Report of the Strategic Director of Planning, Housing and Enterprise. Paragraph 8.7 of that Report states that:

"In essence, the ability to use Green Belt to reduce housing targets requires exceedingly robust evidence (through some form of Green Belt review study) which shows that every part of a district's Green Belt is so essential to the purposes of a Green Belt that none of it can be released. Even if that level of evidence were to be established, the district would still have to consider the sustainability implications of a strategy which deflected their growth elsewhere."

4. This statement illustrates the fact that NHDC has its approach to Green Belt completely back to front. As noted above, the presumption enshrined in the NPPF is that Green Belt boundaries should only be altered in exceptional circumstances. By contrast NHDC is advocating a policy of resisting any reduction to housing target numbers unless it can be proved that every part of the Green Belt is indispensable; and even in the latter case it suggests that that might not be enough if wholesale preservation of the Green Belt would have a knock-on effect for sustainability elsewhere.

5. Paragraph 8.8 of the Report goes on to say that:
"The Green Belt Review finds that there are parts of land which, whilst they contribute to the overall Green Belt, are not essential for the fundamental purpose of the Green Belt of preventing towns from merging. Coupled with the Sustainability Appraisal's finding that it is better to meet needs in such a way that the main population centers of the district are able to take growth, the plan proposes amending Green Belt boundaries accordingly."
6. Again, this reasoning is not in line with the requirements of the NPPF. Amendment of the Green Belt boundaries cannot be justified purely on the basis that parts of the Belt are not essential in preventing the merger of conurbations; if nothing else, paragraph 80 of the NPPF sets out four other basic purposes which the Green Belt serves. Equally, it is not enough simply to say that it would be "better" if the main population centers were able to take growth. Neither of these reasons is in itself sufficient to establish that exceptional circumstances exist.

7. This, then, goes to the nub of the Report's deficiency. At no point are any exceptional circumstances put forward in the Report to justify the Green Belt Review. Indeed the phrase "exceptional circumstances" is not employed at any point in the Report.

8. Some analysis of the existence (or otherwise) of exceptional circumstances was eventually undertaken in NHDC's Housing and Green Belt background paper of 2016 - but given that this paper was produced nearly two years after the recommendation by the Strategic Director (reaffirmed in the Draft Local Plan of 2014) that the Green Belt boundaries be amended, it is difficult to avoid inferring that the background paper was produced in an attempt to back up the unjustified conclusion of the Strategic Director's Report rather than to undertake an objective assessment of whether exceptional circumstances exist.

9. Even if the Housing and Green Belt background paper of 2016 were to be taken in good faith, it provides nothing in the way of specific evidence to support the proposition that exceptional circumstances exist. The paper confines itself to broad generic observations that the objectively assessed needs of the District are considerable; that there are limits to the availability of land suitable for sustainable development; and that the social and economic roles of sustainable development might not be achieved without resort to Green Belt land. None of these reasons is obviously exceptional - indeed the fact that both NHDC and neighbouring authorities are seeking to revise the Green Belt to such a significant extent and in such a blanket fashion strongly suggests that there is nothing remotely "exceptional" about the exercise at all.

10. The Conclusions section of the Housing and Green Belt background paper of 2016 again highlights the back-to-front approach which NHDC has adopted in its thinking. Paragraph 4.90 states that:

"It is clear from both the SHLAA and this analysis that a number of potential development sites in North Hertfordshire are constrained by policy, heritage, ecological or other considerations. It is equally plain that, if the Council were to impose blanket restrictions upon development on any (combination) of the grounds above it would face severe challenges in meeting the identified needs for housing and, albeit to a lesser extent, employment."

It is not for the Council to decide whether to impose "blanket restrictions" upon development on any of the grounds mentioned above. Those blanket restrictions have already been imposed by the NPPF; it is for the Council to determine whether exceptional circumstances exist which allow for those restrictions to be pared back at all.

Equally, paragraph 4.94 of the paper goes on to say:

"Given the number of sites affected, it is similarly considered that any blanket policy of restraint on the grounds of agricultural land quality, surface water flood risk and / or heritage would be likely to impinge on the achievement of sustainable development for the same reasons."

Again, there is already a policy of restraint on these grounds as set out in the NPPF. It is for the Council to explain why it believes that the particular circumstances merit a deviation from that policy.

11. Ultimately there appears to be an unwillingness on the part of NHDC to acknowledge (or an inability to appreciate) that the NPPF does not always allow development to proceed in full, and that the presumption is that the Green Belt should not be touched in normal circumstances. The Housing and Green Belt background paper sets much store by the judgment in the Calverton Parish Council case of last year in seeking to explain its decision-making process. The Council might have done well to pay heed to Jay J.'s observation in that case:

"Review of the Green Belt in the face of sustainable development requires exceptional circumstances. Refraining from carrying out sustainable development, and thereby causing social and economic damage by omission, does not."

12. In summary, then, a reading of the various reports produced by NHDC leads to the conclusion that a decision was made to amend the Green Belt boundaries without any exceptional circumstances being identified; and that a subsequent report intended to provide some ex post facto justification for that decision failed to offer anything other than the most generic and non-specific reasons for the re-classifying of numerous sites.

13. Turning to the specific proposal to remove land at Deards End, Knebworth (Site 52 - Preferred Options KB1) from the Green Belt, I would simply note that the North Hertfordshire Green Belt Review 2016 classified the site as making a significant contribution to Green Belt purposes. In such circumstances NHDC would be expected to provide some compelling reasons for the land to nevertheless have been removed. In the event the only site-specific explanation is contained in a site selection matrix forming an appendix to the Housing and Settlement Hierarchy Paper 2014:
"Ability to make contribution to overall housing requirements and provide infrastructure with potential wider community benefits. Site-specific criteria and proposed dwelling estimate allow for appropriate mitigation of potential impacts and address a number of issues raised through the consultation. On balance, positive opportunities afforded by this site are considered to outweigh harms."
This wording is, if anything, more reminiscent of the test under the first limb of paragraph 14 of the NPPF ("any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole...."), than of the test of what might constitute exceptional circumstances. It is in any event difficult to conclude that the NPPF's concession to exceptional circumstances is intended to be applied in this particular instance - if that were the case, the protection afforded by the NPPF to the Green Belt would be little or non-existent.

See attachment

We object strongly to the proposed housing expansion in Knebworth in the above plan for several reasons :

1. No provision is made to extend the present infrastructure and local services in Knebworth in respect of :
a) traffic flows in the main street where congestion is already a major daily problem;
b) car parking spaces, particularly for commuters - many of the village's streets are already fully used for parking and extends as far as Gipsy Lane on the western edge;
c) pressure on the rail bridges which are narrow with blind bends and very limited
pedestrian access, creating potential safety hazards. In that nearly all of the new housing would be on the west side of Knebworth, use of these bridges for access to village services and the B197 through-route would increase dramatically;
d) road access to/from the new housing areas is via narrow, twisty lanes.
e) demands on the village GP surgery which is already under pressure and with limited parking. The proposed re-location to the current Library site may help a little but at the presumed loss of that facility.

2. Loss of Green Belt land and the consequential harm to the environment and reduction in productive farmland. The plan makes no provision to create wildlife friendly 'corridors'.

3. The problem of increased run-off arising from the huge increase in impermeable surface area, thus putting greater demands on local drainage as well as sewerage.

4. Lack of consideration for the quality of life both for existing and future residents with regards noise and air pollution, demands on local shops and services, and the siting of a proposed new school close to the A1(M). These issues are likely to be exacerbated by the reduction in some rail services with the new residents having to travel for work as the plan does not make provision for increased employment opportunities.

The proposal to increase the size of Knebworth by 31% by building on most of the 'available' non-urban parts of the village without regards for the infrastructure, services, the environment, and quality of life of the community is simplistic and unsustainable. The plan should therefore be rejected and if necessary re-submitted in a more viable form.

See attachment

The following supports my objection to the details contained in paragraphs 13.183 to 13.202 of the Proposed Submission Local Plan.

Legal Compliance
It is obviously difficult for the layman to comment on legal compliance but there have been significant shortcomings in the communication of the proposed plan. No formal communication has been delivered to me personally. I was notified of the proposals by a neighbour. Also the original proposal which was open for consultation did not include site KB4. At best it is extremely poor communication but it may be construed that this section of the plan was not properly open to public consultation.

Sound
Positively Prepared
Sites over 500 homes, with the exception of Knebworth, have been classified as a Strategic Housing Site. Whilst there a 4 separate sites in Knebworth they are close together and in the context of a village they should be considered collectively. This may be a function of the late addition of KB4 taking the number of houses from 463 to 663 (including built and planned)

Justified
Again it is difficult for the layman to comment but there are a number of inconsistencies with the proposal and policies defined in the plan.

There is no description of the "exceptional circumstance" that are required for the removal of the Green Belt particularly for the KB4 site. I am informed that a recent Council review of the Green Belt put a high value on this site. This site is particularly useful in preventing Knebworth and Stevenage from coalescing. As well as being Green Belt KB4 is valuable agricultural land and is under cultivation.

Effective
There seems to be confusion between the definite provision of a primary school in KB2 and the possible provision of All-through secondary school in KB4. Again it looks as if the addition of KB4 has not been fully considered.

Transport provision in Knebworth is already under resourced. The recently proposed changes in the rail timetable combined with a 33% increase in population would mean that Knebworth could not operate effectively as a commuter village. Similarly, the road network, specifically the town centre, is congested already. An additional 663 homes plus the proposed new surgery / library complex in St Martin's Lane will exacerbate the situation even further particularly as section 13.195 basically states that it is a known problem but nothing is going to be done about it.

Consistent with National Policy
I'm not sure whether Section 2 is National Policy but it is certainly inconsistent with the proposals in paragraphs 13.183 to 13.202 of Section 4. Section 2 states that the majority of development will take place in towns and "some growth allowing our villages to thrive". Adding 663 homes (a 33% increase and by far the largest number allocated to any village) to Knebworth and as well breaking the policies set out, will irrevocably change the nature of the village.

Legal Compliance
Given that my objections in this section relate to the consultation process itself nothing can be done to make it legally compliant (if it was illegal in the first place).

Sound
The plan relates to the next 15 years when it only needs to relate to the next 5 years. Given this and current uncertainty in the demand given international events a shorter horizon would appear to be more appropriate.

The area West of Stevenage has been reviewed a number of times but is now being 'reserved' for future use. The use of this site would fulfil a number of the policies better that the proposal particularly in reference to Knebworth and KB4 in particular.

See attachment

I am sending this email to object to the latest NHDC proposal for developing the village of Knebworth:

1. Having lived in Hertfordshire all my life, the last 26 years specifically in Knebworth, I believe gives me a reasonable qualification for this objection to be taken into consideration.

2. As a recently retired mechanical engineer I have no background in council or town planning work, but the Plan appears to display minimal 'joined up' policy across the North Herts district.
- it seems to increase most, if not all, the North Herts district's towns and village footprints merely to 'spread' the housing load, with no attempt to incorporate broader social needs.

- the option of an alternative, a new build Garden City, appears to have been dismissed altogether, despite strong representations from our local MP Stephen McPartland and others.

- the option of any other reasonable alternative does not seem to feature either. Being careful to avoid nostalgia or Nimbyism on my part, there is NO other creative plan proposed that might offer anything else as a realistic alternative to ease the excessive urbanisation of Knebworth proposed in this plan.

- there is no evidence of a structured village layout for Knebworth as a whole; the 31% increase in population will put proportionately more demands on existing facilities. There is no aspect of the Plan that deals with enhanced play/social areas, shopping facilities, affordable homes, a care home within the village (Bulwer Lytton and Dale Villa were both recently demolished and replaced with housing), additional business amenities, etc. - merely a proposal to to cram as many houses into the designated spaces as possible.
- the Plan includes an additional school for Knebworth on Green Belt, MAYBE. Having formerly lived in Broom Grove, Knebworth, the plot of land behind our house was originally reserved for a possible school, but that was shelved and now boasts houses as Bellamy Close.

- the Plan appears to have taken little, if any, of local residents' opinions into account (previous controversial plans have been proposed and met with largescale opposition).
3. The Plan's terminology makes a number of bland, generalised comments that offer no clear picture of what is really planned. Such as:
- 'sensitive designs' for the west side development - the term is meaningless unless constructively qualified e.g. sensitive to maximising the developers' profit margins?

- 'creating an appropriate defensible Green Belt boundary' - again meaningless e.g. appropriate to the developers' minimum budget?
4. Knebworth is already straining under the effect of a significantly increased population (three sizeable housing estates built since 1975 (Orchard Way/Broom Grove, Wadnall Way/Woodstock and Kerr Close/Peter's Way), not to mention significant infilling of previously more spacious private homes and land e.g. Dumelow Court, Wordsworth Court and Constance Court.
- commuter car parking has become an increasing problem in roads close to the railway station e.g. Hornbeam Spring and Park Lane are particularly congested throughout the week for residents and through traffic alike. The provision for railway station parking is negligible.

- the road infrastructure has a mixed provision for access, although over the last 10 years or so has become significantly worse e.g. whenever the A1 motorway is restricted due to an accident or road works, then the traffic will largely defer to the old A1 route through Knebworth High Street. Traffic volume to and from Stevenage has also increased in line with its population - particularly noticeable on a Friday afternoon/evening as traffic regularly queues back into Knebworth to cope with the Roebuck Tesco traffic lights (an additional 'windfall' 70 houses and roundabout are currently being muted to add to this existing traffic constriction).
- some roads have become particular pinch points/'rat runs' as drivers seek to avoid build ups elsewhere e.g. Pondcroft Road built at the time of the railway over 100 years ago is now parked both sides and Deards End Lane as struggles as a narrow residential road. The three Knebworth railway bridges also create restrictions to the existing traffic flow.
5. One of the proposals is to completely remove the business site of Chas Lowe's at the centre of the village and replace it with housing. Apart from providing a significant number of jobs locally, Lowe's attracts a sizeable amount of indirect business as its staff, tradesmen and delivery driver's make use of the other village facilities. Traffic is occasionally restricted by drivers delivering, collecting or transferring goods at Lowe's but significantly more traffic delays are incurred by wide berth vehicles struggling to pass through e.g. buses, lorries, 4x4's. Restricting High Street parking will only jeopardise local business and there are no plans to increase off-road parking.

6. I cannot speak with authority on the increased demands for services, specifically including sewage, but understand there are potential limitations at Rye House that still have to be addressed. Additionally, rainwater flooding continues as a long term problem with Gypsy Lane and Orchard Way - adjacent development will likely exacerbate this. Resolution of both sewage and rainwater issues has merely been glossed over in the Plan with still no definitive outcome.

7. Although not a surprise, it was a pity NHDC could not send a representative to the recent Parish Meeting to answer villagers' questions. A couple representing Codicote were in attendance and expressed disappointment at the apparent lack of NHDC in coordinating the Plan amongst neighbouring villages. Similar concern has been voiced by Woolmer Green and Welwyn residents.

In conclusion, my overriding disappointment with the Plan is rooted in the fact that my wife and I specifically chose to live in Knebworth because we wanted to live in a village with a village character. The scale of this development will radically and adversely undermine that special quality to the point it will no longer be relevant.

I hope my comments will go some small way to persuade those involved in the planning stages that a major overhaul needs to undertaken before this Plan progresses any further.

I am writing to object to the proposed development for Knebworth in the local plan, as detailed in paragraphs 13.183-13.202.
My general objections to the local plan as it affects Knebworth are as follows:
1. Lack of a cohesive strategy which means the plan is not effective. There is no correlation or cohesion between the additional housing and the infrastructure needed to support sustainable growth.

2. The number of houses proposed. The plan proposes 663 dwellings, which would be a 30+% increase in the size of the village. There are existing issues with traffic flow, parking, train and school capacities which would be negatively impacted by an increase in population. In addition, the extra impact of a further 150 homes proposed for Woolmer Green has not been considered.

The negative impact that this additional development would have on the village cannot be justified when the land west of Stevenage is reserved for 3,100 homes.

3. The removal of significant sites of green belt from around Knebworth, contrary to government policy. There are no demonstrable exceptional circumstances detailed that justify the removal of land from the green belt. The green belt contributes significantly to protecting the space between Knebworth and surrounding towns and villages, thereby maintaining the separate identity of Knebworth as a village. With the removal of land from the green belt, there would be increased coalescence between Woolmer Green to the south, Bragbury end to the east and Stevenage to the north.

The impact on the countryside and landscape would be detrimental, and would change Knebworth and its surroundings for ever.

4. The negative impact on highways and other transport. The B197 is used as an overflow for the A1M, and at certain times during the day is already congested. Further development would increase the number of cars on the road and journeys taken, thereby adding to the congestion. As mentioned above, the train capacity at peak times is already compromised, cuts to the service are being proposed by the train company and so an increase in population will inevitably have a negative impact on the service available.

5. Drainage issues. There are already major capacity issues at Rye Meads Sewage Treatment Works. Additional development would add to the capacity issues, not alleviate them.

6. A negative impact on the local economy. There does not appear to be any consideration of the local economy in the Local Plan; there is no proposal for job creation and none of the land proposed for removal from green belt is a set aside or allocated for commercial development. In fact, a significant site in the middle of the village currently used for commercial purposes (KB3 Chas Lowe) is being reallocated to housing, which is the reverse of a local economy or commercial development.

In addition to my general objections above, I will be most affected by development of land at KB4, land east of Knebworth (ID278). I object to the development in this area on the following grounds:

1. First and foremost, the land is green belt. As mentioned above there are no exceptional circumstances that justify the removal of this land from green belt. If it were removed, there would be significant danger of coalescence with Bragbury End and Stevenage. In addition, it would have a very negative impact on the open, picturesque landscape in that area of Knebworth.

2. The road network around the proposed development is insufficient and inappropriate to cope with the increased traffic flow. The roads that would most impacted by the development, namely Watton Road and Swangleys Lane (both restricted width country lanes), St Martins Road (private road) and possibly Oakfields Road are all minor roads, most of which already struggle to cope with modern traffic flows. Additional development would inevitably result in additional vehicles and journeys, thereby compromising the routes further.

3. The land is currently agricultural. If the land were to be removed from the green belt there would be a loss of productive agricultural land, with no proposals to replace this productivity elsewhere.

Knebworth is a thriving village with a strong community spirit. Please don't destroy it.