KB1 Land at Deards End

No convincing case has been made for building on Green Belt land. Deards End Lane is highly hazardous for both drivers and (in my case) walkers. I see no way it can be widened. The A1(M) is very noisy when the wind is in a certain direction; people living in the proposed houses would have the noise (and pollution) all the time. The Conservation Area would cease to have any meaning. The railway bridge is a particular 'pinch point'. It cannot take heavy traffic, and if this development goes ahead, it would have to.

The land at KB1 (Deards End Lane) is designated green belt land. No exceptional circumstance exists which would lead to the conclusion this land needs to be developed.

The land is bound at its western side by the A1(M) and subject to atmospheric and noise pollution from the motorway; it is not suitable for permanent housing.

No provision has been made for any future widening of the A1(M) which is two-lane through its Knebworth section.

Access is difficult due to local narrow lanes and low bridges.

Neither justified, effective nor consistent with NPPF:
- Development would be contrary to government policy on Green Belt as set out in the NPPF. NHDC have not demonstrated that "exceptional circumstances" exist for the development of the site. Housing need alone is not a sufficient justification, as confirmed by the Minister of State in August 2016 in a letter to MPs.
- This particular tract of Green Belt is important because it prevents the encroachment of Knebworth into the countryside to the west.
- The site is located between the A1(M) and the western edge of Knebworth Village and is affected by traffic noise from the A1(M). The adjacent stretch of the A1(M), between Junction 6 and 7, is poorly-rated in the recent Highways England report (AI East of England Strategic Study, June 2016). There are high levels of congestion, accidents, and noise. The building of housing on this site would impact on the future viability of any plan to widen the A1(M). such a scheme cannot be ruled out, given that this section of the A1(M) is one of the most heaVily-congested in the UK.
- The amount of traffic generated by about 200 new dwellings would add considerably to the levels of traffic impacts on the B197. Congestion levels in the centre of the village would be exacerbated.
- There would also be pressures on the Deards Lane End Lane railway over-bridge, which is a Scheduled Ancient Monument. Increases in traffic are likely to have an adverse effect on the structural integrity of the bridge, which crosses the East Coast main railway line.
- To the east of the site is the Deards End Conservation Area, the character of which would be severely affected by the proximity of so much new housing and the increased levels of traffic. With a potential link to Park Road, and north-south movement through the village limited by three narrow railway bridges, there is a clear risk that a "rat run" would be created by drivers seeking to access Stevenage from both KB1 and KB2. Deards End Lane is a narrow single track road with no pavements, giving rise to safety concerns for all road users as well as pedestrians.
- The infrastructure improvements suggested by the District Council are impracticable. Any road widening would have an adverse effect on the character of the Conservation Area, and would involve the loss of residents' gardens.
- Potential effect on the Knebworth Woods SSSI, to the west of the proposed development, and an area of ancient woodland adjacent to the site. Both areas are protected habitats

The proposal to move Green Belt boundaries from their current long established position solely because there is an equally or more defensible location elsewhere is contrary to national Green Belt policy. The availability of land, offered to meet a perceived housing need, is not an exceptional circumstance, and does not justify the removal of Green Belt status.
The removal of Green Belt status from the land affected would be likely to cause significant harm to the Green Belt and its purposes, and requires fuller explanation and justification in the Local Plan.

The plans as a whole are not sound:

Traffic:
Knebworth already suffers from congestion and insufficient parking provision, leading to commuter parking in the residential areas near to the station and potentially dangerous congestion in the high street. These proposals would exacerbate the above problems and also lead to increased access traffic through residential areas such as Gypsy Lane, Stockens Green and Deards End Lane, none of which are suitable for use as through roads: Deards End Lane and Gypsy Lane are single track roads constrained by rail bridges which would have to be widened to permit greater access whilst Deards End Lane and Stockens Green are conservation areas.

A1
The proximity of the proposed development to the A1 is problematic. Noise and air pollution would be significant, the impact of which could only become worse as traffic levels increase. The proposals run contrary to the Environmental Audit Committee's aspiration that Councils should ensure that they "prioritise air quality in planning decisions" .

Green Belt :
The developments encroach upon significant elements of Green Belt which is contrary to national policy.

Sewerage:
The plan as a whole could exceed the constraints imposed by the current capacity of the sewerage system serving the area. This constraint led to previous plans for development to be abandoned and is not addressed in the current plan

Public Services
There is no commitment - only suggestions- to provide public services which will cope with an overall increase of 31% in the size of the village. Medical services, schools and access will all be affected and cannot be considered beyond the scope of plans of this scale.

The plans are not justified:
- No justification or consideration is given to the economic impact of the plans on the village e.g without increased local employment impacts on roads and railway are likely to be exacerbated
- the plan provides for a disproportionate rate of growth in Knebworth vis-à-vis other parts of North Hertfordshire which does not seem equitable
-the plans require removal of green belt land without any other justification than construction of housing
- benefits which the plan could provide - eg. improved medical services; greater access to school of choice, particularly secondary; stimulation of local businesses and increased employment opportunities; rail station development alongside improved services - are either ignored or given token consideration

There is no plan in place to address the highways issues, specifically the railway bridges.
The drainage issues have not been addressed.

Knebworth is a village surrounded by Green Belt. To remove the Green Belt is a threat to the village, it will become connected to Stevenage and Welwyn Hatfield.
The plan cannot be effective as their is no strategy. There is no connection between housing, employment and creation of an infrastructure needed to support the growth of such a plan.
Impact on the B197 has not been taken into consideration, currently the B197 takes large amounts of commuter traffic morning and evening in both directions. Presently the time to travel 3 miles to junction 6 of the A1 or the centre of Welwyn Garden City takes 45minutes.
Parking at the Railway Station is a major problem. Knebworth has the highest growth of rail passengers in the region. Govia Thameslink is proposing a cut in trains stopping at Knebworth.
There are no employment opportunities in Knebworth, the current largest employer is closing the business. There is no opportunity nor are there proposals for employment in the area.
Access to the proposed site is severely restricted, the only access road is through a narrow hieight restricted bridge. Due to parking it is a single track road through the village.
There is a major capacity issue at Rye Meads Sewage Treatment Works. There are issues with the closeness to conservation areas, there not being a plan to provide commercial properties that can support an enlarged village.
The impact of noise and pollution from the A1(M) this stretch of the motorway is recorded as the most polluted at commuting times. Traffic will use Deards End Lane, mostly a single track road with a narrow weight restricted bridge. Currently a rat run for traffic avoiding the centre of Knebworth. That road would be unable to cope with increased traffic flow.

This site with a proposal for approximately 200 dwellings is the most sensitive for development as it is an area of great landscape value and has the highest point in Knebworth village at the Black Pits pond. The NHDC Land Sensitivity and Capacity Study Report - Planning Policy and Projects, November 2006 identified only three Knebworth sites with low sensitivity and high capacity. In each of the three cases the report states "these sites have been appraised as being able to accommodate new housing development without significant effects on their character or the surrounding landscape." KB1 is not one of these sites.

The NHDC Land Allocations - Additional Suggested Sites July, 2009 highlighted the site's weaknesses as:

i. Green field site as grade 3 agricultural land

ii. Adjoins a conservation area

iii. Site is groundwater source protection zone 2

iv. Site is located next to the A1M

v. Identified constraints on utilities and capacity of primary school

Council's weakness iv above has recently been reinforced by the Department for Transport in their A1 East of England strategic study: interim report of August 2016 which concluded, inter alia, that parts of the A1 are located unacceptably close to residential locations, causing unpleasant environmental conditions for local residents. It is hard to understand how moving Knebworth closer to the A1(M) is consistent with this very recent government finding.

The site has a mature hedge and tree line running north to south across the high point abounds with wildlife. In summary the site has the capacity for new dwellings but no other attributes and would be a highly visible ugly 'carbuncle' between the conservation area and the A1M.

My objection to the Plan is the failure of the Council to justify a long series of proposals for the removal of land from the Green Belt around towns and villages. Such justification should have specifically included the demonstration by the Council of the 'exceptional circumstances' for removing land from the Green Belt on a site by site, and settlement by settlement basis, and setting them out in the Plan. Instead, the Council appears to have relied on a blanket assumption that all housing and other development needs, not just in the District but in Stevenage and Luton as well, identified through their background studies, must be met in full, despite national planning policy and planning case law to the contrary. If the Plan is allowed to proceed as published by the Council, it would commit future generations to continuing development which would cause incalculable harm to the Green Belt.

I believe that the Council has not considered all reasonable alternative approaches to meeting the District's development needs, particularly when setting a Housing Target, and that this failure has contributed to an unsound Strategy. A realistic contribution to housing capacity from a greater range of sources including windfall sites, changes of use in accordance with current permitted development rights, and other measures promoting the recycling of previously developed land and property, should have been included in the Plan, and a Housing Target then determined that reflects both development needs and the nationally important constraints that exist in this part of Hertfordshire.

The proposal to move Green Belt boundaries from their current long established position solely because there is an equally or more defensible location elsewhere is contrary to national Green Belt policy. The stated reason for doing so is not an exceptional circumstance, and is not justified. The removal of Green Belt status from the land affected would be likely to cause significant harm to the Green Belt and it's overall purpose.

I object to the development of the site KB1. If this site is developed, it will mean a loss of green belt land to the west of the village which will be detrimental to the well-being of all its residents. The wide range of flora and fauna in this area will be seriously affected by the projected development.
This site is not suitable for development as it is close to the A1(M) and therefore suffers from serious pollution of both noise and air quality.
There will be a detrimental effect on the Deards End conservation area if this site is used, particularly with the extra amount of traffic passing through the conservation area in order to access the homes.
The current GP practice in the village is severely stretched. They try to do their best, but it is obvious to all that when you have to wait 10 days to get a routine appointment at the surgery, there is no room for further residents to be signed up. There has been a noticeable decline in the number of partners and the turnover of staff at the surgery over the last two years; it is hard to see that more staff can be recruited to deal with any more residents.
Sites KB1 and KB2 in Knebworth are both less well suited to development than other sites in the area through their lack of vehicular access. There are three access points across the railway, two under and one over bridges; as I use these bridges daily, I am only too well aware of the lack of space, each one is almost single track for vehicles and I often have to wait for a vehicle coming in the opposite direction to finish their manoeuvre before continuing. The pedestrian footpath under or over these bridges is only wide enough for one person, currently, pedestrians have to dangerously move into the road in order to pass each other. If the village were to increase by 31%, I cannot see how these access points would cope.
In the construction phase, which is planned to take 15 years, how will the construction vehicles access the sites when they too have to either pass over or under the railway bridges or access from Codicote down winding country lanes?
There is currently little direct employment within Knebworth, thus nearly all residents leave the village for work. Over the last year the traffic using the B197 has increased considerably. The journey to the A1(M) which used to take 5 minutes can now easily take 20 minutes at 7.40 a.m. I believe this to be because of the amount of school traffic, both private and school buses, and the number of people joining the road from side turnings. If the number of homes in Knebworth is increased this road will become further blocked with health and economic ill results.

I object to the development of the site KB1. If this site is developed, it will mean a loss of green belt land to the west of the village which will be detrimental to the well-being of all its residents. The wide range of flora and fauna in this area will be seriously affected by the projected development.
This site is not suitable for development as it is close to the A1(M) and therefore suffers from serious pollution of both noise and air quality.
There will be a detrimental effect on the Deards End conservation area if this site is used, particularly with the extra amount of traffic passing through the conservation area in order to access the homes.
The current GP practice in the village is severely stretched. They try to do their best, but it is obvious to all that when you have to wait 10 days to get a routine appointment at the surgery, there is no room for further residents to be signed up. There has been a noticeable decline in the number of partners and the turnover of staff at the surgery over the last two years; it is hard to see that more staff can be recruited to deal with any more residents.
Sites KB1 and KB2 in Knebworth are both less well suited to development than other sites in the area through their lack of vehicular access. There are three access points across the railway, two under and one over bridges; as I use these bridges daily, I am only too well aware of the lack of space, each one is almost single track for vehicles and I often have to wait for a vehicle coming in the opposite direction to finish their manoeuvre before continuing. The pedestrian footpath under or over these bridges is only wide enough for one person, currently, pedestrians have to dangerously move into the road in order to pass each other. If the village were to increase by 31%, I cannot see how these access points would cope.
In the construction phase, which is planned to take 15 years, how will the construction vehicles access the sites when they too have to either pass under the railway bridges or access from Codicote down winding country lanes?
There is currently little direct employment within Knebworth, thus nearly all residents leave the village for work. Over the last year the traffic using the B197 has increased considerably. The journey to the A1(M) which used to take 5 minutes can now easily take 20 minutes at 7.40 a.m. I believe this to be because of the amount of school traffic, both private and school buses, and the number of people joining the road from side turnings. If the number of homes in Knebworth is increased this road will become further blocked with health and economic ill results.

1. The green belt surrounding Knebworth makes a significant contribution to protecting the space between the village and the surrounding villages and
Stevenage. Removing it will likely mean there is a considerable danger of
coalescence, destroying the identity of Knebworth. Developing KB1 will remove the green-belt buffer on the west of the Knebworth.
2. KB1 is next to the A1(M) - not only will people living in houses built here suffer from noise pollution, this section of the A1(M) is the most congested and polluted part of this motorway.
3. Access to KB1 is an issue. Deards End Land is a narrow road with a narrow railway bridge unsuitable for heavy traffic. The plan needs to include new, wider, access routes to KB1.
4. KB1 includes a conservation area. This will be damaged if this area is developed according to the current plan. Furthermore, there will likely be a negative impact on wildlife and Knebworth woods site of special scientific interest. The plan needs to include safeguards to preserve these areas.

Deards End Lane is a Conservation Area. Building additional dwellings will cause several problems. The green belt buffer between Knebworth and Stevenage will erode more and more. There is the risk of damage to the character of the Conservation Area. Today Deards End Lane is often used as a rat run between Park Lane and Stevenage Road and that will only get worse. The road is too small for lots of traffic and the Railway bridge is too narrow especially on the South Side of the Bridge. Seeing how the situation is now will make this an impossible situation when 200 additional dwellings will be built here. A similar problem exists at the Railway Bridge on Park Lane/Station Approach. This bridge is too small and the additional traffic of 200 dwellings will be dangerous for cars but mostly for pedestrians who have to walk over a small footpath.This plan is not positively prepared in considering the different sites in Knebworth independently. None of the sites exceeds 500 but combined they do and they should be considered as a whole because they will all together have a considerable impact on the village and should be thought through. As it stands there is no strategy and without this the proposal is wrong. The plan is not justified: other sites should be considered. It is wrong to grow a village by 31%.

The plan will remove the Green Belt buffer to the West of the Village and potentially damage the character, habitat and species on wildlife sites of the Deards End Conservation area, and Knebworth Woods site of special scientific interest. Any houses built in this
area will be subject to pollution from the busy A1M
Access to the new development would primarily be through the narrow Deards End Lane and also across the narrow railway Bridge which is not suitable for heavy traffic.
Railway Bridge.

This site is only accessible via small lanes or via a narrow railway bridge. No consideration has been given to the traffic congestion that would result from any large scale development. It is also adjacent to, and would present a serious risk to, the wildlife and habitats in the adjacent Site of Special Scientific Interest. It would unjustifiably destroy Green Belt buffer between Knebworth and Woolmer Green and does not take into account the proposed development of Woolmer Green.

Green Belt — removal of Green Belt buffer to west of village
* Impact of A1(M) — noise and pollution from A1(M)
* Deards End Lane and Railway Bridge — traffic congestion on narrow Deards End Lane and on narrow railway bridge unsuitable for heavy traffic
* Effects on Conservation Area — damage to character of Deards End Conservation Area
* Potential harm to habitats and species — impact on wildlife sites and Knebworth Woods site of special scientific interest.

to support these additional homes, cars and people there would need to be proper expansion of local infrastructure

It is our view KB1 and KB2 should be treated as one development rather than the two currently listed. Positioning of the two sites and the issues relating to the two sites are the same.

We feel the number of dwellings proposed are too high for this location both in terms of their proximity to the A1M (its busiest section between Junction 6 and 7, and the consequent impact on the village, its existing and future residents.

No account appears to have been taken for the number of vehicles each dwelling will have and the effect of this increase in the village.

Knebworth Village is already severely impacted by poor transportation planning, extremely heavy road traffic through the village and the peripheral roads. Access from KB1 to London Road and Stevenage Road will in the main be via Park Lane/Station Road and the railway bridge or via Gun Lane to Gun Road and the railway bridge. The latter is likely to be more commonly used as it would avoid the currently bad traffic jams heading north to south through Knebworth Village in the morning and vice versa in the afternoon/evening. More cars, more traffic, more pollution for the existing and new residents of Knebworth Village.

Knebworth Village is served by a relatively small railway station which also caters for commuters from surrounding villages and, also, Stevenage. I understand commuter usage through Knebworth Railway Station had increased 70% in the last ten years. Access to the Railway Station is through Station Road/Park Lane. KB1 is going to contribute both further infrastructure and transportation problems to this area and for the future residents of KB1.

We also believe that KB1 is an assault on the Green Belt which has clearly contributed to the continuance of local fauna and flora in the area, contributed to defending, albeit on a small scale, the local environment from the impact of the increased traffic and the consequent pollution from the A1M.

The Green Belt has also been a significant barrier to coalescence between Stevenage and Knebworth. The approval of KB1, along with the approval of the Odyssey development off Old Knebworth Lane, would make coalescense with Stevenage inevitable. In addition, coalescence with Woolmer Green becomes a certainty as development planning continues along the B197.

Schooling, health and social amenities will all be impacted by a development of this size. Primary schooling in the village is already stretched by both Knebworth children and children from other villages. Secondary schooling is non-existant and children travel to Stevenage or Welwyn Garden City for their continued education.

An increasing young population will only exacerbate what is already a poorly provided area. This Local Plan does not provide, in any coherent way, for this growth and the negative impact on the Village infrastructure, its residents, environment and local habitat.

While we are not, per se, against the building of new dwellings we believe the numbers proposed are signifcantly higher than the Village needs or can manage. This Local Plan for Knebworth Village in its current form is therefore unacceptable and should be significantly reduced or rejected.

This Local Plan must include a comprehensive review of the existing transportation links and whether it is future-proofed to sustain a development such as KB1. Nothing in this plan suggests it looks beyond the building of a high number of dwellings other than to meet a target and tick a box.

This is green Belt Land and is contrary to government policy it is important to prevent encroachment of Knebworth into the countryside to the west it is also located next to the A1 (M) and traffic from this site would have considerable impact on the B197. Deards End lane is a narrow single track road with no pavement it would put pressure on the railway bridge which is an ancient Monument.
It is also adjacent to ancient woodland with protected habitats.

Increase in already above average, pollution levels.
Increased risk of flooding from an already high risk, high water table area.
local infrastructure insufficient for increased population and road usage.
Removal of green belt

Development of this site would cause a detrimental loss of the green belt and loss of openness and damage to the character of the village of Knebworth. There is insufficient local infrastructure to support this number of additional occupants of Knebworth and traffic in Knebworth would increase drastically which Knebworth cannot accommodate.

If this site is developed it will result in loss of the greenbelt and loss of openness of the greenbelt. It will also remove the buffer between Knebworth village and the A1M motorway.

Driving in the area around Deards lane is already difficult and the roads will not cope with this increased traffic. This will also result in removal of the green belt and loss of valuable green spaces. In addition the number of houses proposed will increase the size of the village considerably and no credible has been put in place for schooling/doctors (already nearly impossible to get an appointment). The current drainage cannot cope with heavy rainfall with newer houses already liable to flooding.

Due the already over congested B197 at peak times during weekdays the suggestion to introduce 200 house on this site (potential 200 plus cars) and 600 houses in Knebworth generally (600 plus cars). The area is unsafe and unsound as a location for additional Housing. The strain will push the local community infrastructure (Doctors, Schooling and Railway Station) beyond breaking point.

Additionally, the only access point to this location is under or over very narrow railway bridges, which already poses a road safety risk for pedestrians.

I feel that this development is too large, especially as there will be a similar sized one close by. Knebworth is already struggling with transport and heavy congestion , making most of the roads a rat run.
There is currently a need for a secondary school in theis area as all children of this age have to travel out of the village to access their education. There is no mention of extra provision for children under statutory age and current providers are full to capacity at the present time, so where will all these new families go?

This site is on land adjoining, on its western boundaries, the A1(M). This presents three issues.

Firstly, any new housing sited next to a busy arterial Motorway is surely undesirable and subject to regulation and constraint on the ground of noise and air pollution.

Secondly, and more importantly, the Government has announced in 2015 the
reinstatement of the Widening project for the A1(M) between J6 (Welwyn) and
J8 (Stevenage North). Clearly additional land to the East and West of the current Motorway will be required to allow for the widening and this will no doubt encroach into the site. The details of the A1(M) widening will clearly need to be taken into consideration before the proposals for this site can be settled.

Finally, the creation of this site will remove the Green Belt buffer between the village and the A1(M).

Knebworth is dissected by the London, Kings Cross to Edinburgh Railway line with the main road through the village, the B197, being to the east of the railway line. This proposed site is to the west of the railway line. Thus any / all vehicles wishing to go from this site to Stevenage or Welwyn (or further afield) need to cross over or under the railway line by one of three bridges on Gun Lane, Station Road or Deards End Lane.

All three of these bridges have narrow roadways that frequently mean vehicles have to wait at one end or the other as it is hazardous for vehicles to pass in a two-way manner.

Additionally, whilst the roads on these three bridges are narrow, the pavements for pedestrians are even narrower and, if being constructed today, I'm sure would be less than the safe permitted width. Pedestrians frequently have to step into the road to avoid one another and it is a miracle there have not been many accidents over the years.

The increased vehicle traffic from an additional 200 dwellings, will provide unwarranted congestion and danger to road user and pedestrians alike at these bridges.

I object to the Site KB1 based on;
- Impact of rise in traffic congestion not only on the narrow lanes of Deards End Lane, Railway Bridge by Knebworth Golf Club, but its surrounding filter roads to main roads, such as Park Lane and its Station Bridge. This is already a hazardous journey for pedestrians and traffic as a whole.
Any housing, would damage the character of Deards End Conservation Area and impact on wildlife sites and Knebworth Woods site of special scientific interest.

Many areas of consideration for whether this would work
Highway infrastructure
Public transport
Release of green belt land
Infrastruction implications

Economic Factors:
Point 1.7 of the LP confirms the aim to 'protect existing Green Belt and only alter it in exceptional circumstances'. In order for a housing development to be considered 'exceptional circumstances' I would argue that provision must be outlined in the LP for affordable housing schemes. The local plan suggests that 'homes must address the impact they may have on the environment and most of all meet the needs of our local population including ensuring that our families can afford to live here and that the right type of homes are provided for them'
As there has been a 20% rise in house prices over the last two years affordable housing in North Hertfordshire is a serious issue, with the average house price in the district 'well above the regional and national averages' as highlighted in point 2.22 of the LP. With 'currently more than 1,600 households on the local authority housing register awaiting assistance with their housing needs' it is an oversight for the LP to fail to include a guarantee of provision to meet these needs and therefore justify the exceptional circumstances of building on the Green Belt. The LP acknowledges the 'need for more affordable housing' but makes no attempt to confirm that affordable housing or social housing will be assured within the new developments.
Environmental Factors:
Key environmental factors in the Knebworth development sites refer to preservation of green belt land and aesthetics, as well as mitigation of drainage strategy in existing surface water flood risk issues. As there are several types of Sustainable Urban Drainage Systems, the LP should be revised to outline which systems will be put in place for sites KB1 and KB2 so a proper assessment of environmental impact can be undertaken.
According to the NHDC Green Belt Review, listed as supporting evidence for the LP, the Green Belt along the A1(M) corridor to the south of Stevenage 'plays an important role in preventing sprawl' which was of course one of the primary reasons for setting up the Green Belt. It should be considered that 2 of the development sites, KB1 and KB2 are proposed for building on this specific stretch of Green Belt land. The finding of the review states that the Green Belt along the A1(M) corridor 'overall makes a significant contribution to Green Belt purposes, helping to prevent sprawl, merger and encroachment' and therefore the development on this land should be fully justified as extraordinary circumstances in the LP. The Green Belt separating Stevenage and Knebworth performs a significant function, as opposed to the Green Belt to the east of Luton which currently performs a limited function in terms of the preventing the merger of towns;. With the development of site KB1, Knebworth and Stevenage will be separated by the Private Golf club only, leaving the separation of Knebworth and Stevenage tenuous.
Transport and Congestion Infrastructure:
The LP does not go into much detail on the provision of transport infrastructure despite point 2.76 acknowledging that 'The District has a considerable daily outflow of commuters, to highly skilled employment areas mainly in central London'. I would like to enquire as to whether the LP will be revised if the proposed changes to Great Northern Rail provision between Cambridge/London and Peterborough/London as the reduction in services stopping at Knebworth at peak times will have a severe impact on overcrowding at Knebworth Station for commuters. Growth in commuters by train has increased by 71% in the last decade compared with a 48% increase in Hitchin and Letchworth. The addition of 600 new homes in Knebworth would also increase the number of rail users and contribute to overcrowding on services. The LP states that investment plans of key infrastructures and utilities providers including Network Rail, Highways England and Thames Water' have been taken into account but the proposed changes to rail services affecting Knebworth from 2018 has not been acknowledged in the LP.
I notice that clause 13.195 of the LP states 'Our transport modelling does not identify any specific mitigation scheme requirements for Knebworth.' This is an extreme oversight as several roads in Knebworth already experience congestion and an increase in population will exacerbate this. Most notably, the high street which has been acknowledged in the LP as a 'pinch point, particularly when delays or incidents on the A1(M) result in the B197 being used as an alternate route'. However, no change to transport infrastructure has been outlined in the LP. Whilst I understand the point made in 13.197 that 'Highway management measures, such as the use of Traffic Regulation Orders (TROs), lie outside the direct control of the planning system and it is therefore not for this Local Plan to dictate the most appropriate solution(s).' I believe exploration into possibilities before the LP is approved is important. In particular, the provision for 14 homes on the KB3 site directly located on the village high street will increase congestion in that area and has not been addressed by the local plan.
Additionally, the LP acknowledges the transportation infrastructure issues surrounding sites KB1 and KB2 in relation to the Deards End Lane Railway Bridge, a scheduled Ancient Monument that is often too narrow for two vehicles to pass at the same time. The additional almost 400 houses in sites KB1 and KB2 will increase Deards End Lane traffic heavily as an access route into Stevenage if additional roads are not constructed to draw traffic away from Deards End Lane and Gypsy Lane near sites KB1 and KB2, and the LP currently makes no mention of action to be taken on these points.
In addition, point 13.199 indicates that 'Sites in Knebworth will need to ensure that any transport assessments appropriately take these issues into account and contribute reasonably to any necessary mitigation measures'. With Deards End Lane Railway Bridge being a Scheduled Ancient Monument, will plans for other routes into Stevenage that avoid Deards End Lane and Gypsy Lane be considered?
As the LP refers to the NHDC Infrastructure Delivery Plan September 2016 as a representation of the LP for infrastructure, it is necessary to note that the Local Transport Plan 3 encourages 'support for new development to be sited and designed so that maximum use can be made of sustainable modes, including bus travel, in order to access services'. The Infrastructure delivery plan also acknowledges that local bus services are 'patchy in rural areas', running infrequently in Knebworth. The proposed new developments would put further strain on bus services to and from the village. There being 'no specific proposals or funding' for a mitigation scheme for Knebworth transport despite 'existing highway issues - for instance in Knebworth' is a major oversight in the LP and a barrier to resident acceptance of the plan.
The LP acknowledges that it will be necessary to 'work with the Highway Authority when taking forward the development sites set out in the Local Plan. Work on the next iteration of the LTP -the 2050 Transport Vision- is well underway and expected to be finalized by the end of 2016' It is impossible for residents of Knebworth to respond to transport infrastructure issues until the next iteration of the LTP has been released, and I therefore suggest the period of consultation should be extended until after the release of this plan.
Logistic and Location Factors:
The LP references the Statement of Community as reason for easing the 'unmet needs from Luton'. Whilst the developments in North Herts arguably have the space to accommodate this need, it may not be logistically sound. If demand for housing in Luton is high, this suggests people already working in Luton and surrounding areas are driving the demand. With the LP's already acknowledged that 'no rail links from the District to the west exist, meaning towns like Luton and Milton Keynes are less accessible via public transport'. This would put additional strain on road traffic and already strained bus services as those commuting West into Luton and surrounding areas will be forced to commute by car.
GP and Health Services Provision:
Currently the Knebworth Medical Practice has 33 patients per square meter with absolutely no spare capacity for additional patients. This contrasts with the relatively lower patients per square meter in Hitchin and parts of Letchworth. Considering best practice principles suggest that 'the number of registered patients at that practice should not exceed a density of 20 patients per square metre' there is clear evidence that the Knebworth Medical Practice cannot be expected to cope with additional patients. The LP presents that 'an application has recently been submitted for a new library, doctors surgery and pharmacy on the site of the current library' but makes no further mention of this. I suggest that the LP should make provision for these facilities to be approved prior to the plan being accepted, as should the application for these facilities be declined; the village would not be able to cope with the new developments of the LP.
Waste Water:
In the NHDC Infrastructure Delivery Plan, Thames Water's evaluation of sewerage capacity for Knebworth suggests 'Further consideration of sewerage capacity needed and issues with the foul sewer system needs reviewing as the village does not have a dedicated surface water system.'

As a doctor of medicine, I object to development KB1, because a large number of people will live very close to a busy motorway.
It is proven that poor air quality, from vehicle emissions, increases the risk of death from asthma and other respiratory conditions, sudden cardiac death, and overall mortality.
See http://newsroom.heart.org/news/living-near-major-roads-may-increase-risk-of-sudden-cardiac-death-in-women?preview=6a78 and
http://webarchive.nationalarchives.gov.uk/20140505104658/http://www.comeap.org.uk/images/stories/Documents/Reports/comeap%20the%20mortality%20effects%20of%20long-term%20exposure%20to%20particulate%20air%20pollution%20in%20the%20uk%202010.pdf
We should not build high-density housing next to a motorway, which is about to be expanded to three lanes.
The additional traffic will also spoil the Deards End Lane conservation area; Deards End Lane will be turned into a busy rat-run, with traffic queueing to pass in each direction. There is no footpath; pedestrian casualties are inevitable.