KB1 Land at Deards End

I write to register my objections to the proposed housing developments at Knebworth as suggested in the draft development plan from NHDC. Knebworth is a pleasant place to live - the addition of a further 600+ dwellings may change this permanently. My objections are mostly in the "soundness for North Herts", camp.

Parked vehicles in the roads surrounding the station and the high street currently prevents an even flow of traffic. This affects both traffic coming through the village and local people going about their business. Travel from my house in Deards End Lane to the A1 between 8.30 and 9.30 am can take as long as 40 minutes due to queuing traffic on a normal work day. If there is a problem on the A1M then this time can easily extend. Indeed, if the A1M is closed all traffic is routed through Knebworth and queues quickly build up at both ends of the High Street. Adding another 1000 local vehicles to this situation can only make it worse. KB1, KB2, KB3 and KB4 all affect this.

On the same track, vehicular access around the village is hampered by the physical barrier of the existing railway route, which effectively splits the village. The three bridges which provide the links were built in times when motor vehicles were rarities. They are ill suited to the size; numbers and frequency of the traffic they now must support. These "pinch points", will not cope with the additional traffic volumes that will result from the building of 600+ additional dwellings.

Access to the KB1 and KB2 developments is planned to be from the existing Park Lane route. This road is already congested, made difficult to pass by parked cars for the station and is used as a "rat run" by traffic which has chosen to avoid the congested High Street. In its current state, it will not cope with additional traffic to and from the 350+ new dwellings.

I have already mentioned the current parking problems in the village. One of the main contributors to this is commuter parking for the railway. As rail fare prices have increased and parking costs have increased at other nearby stations, the number of workers coming to Knebworth to commute by train has increased. This is not just in roads adjacent to the station as it now affects roads up to 20 minutes' walk away. Increasing the housing stock of the village by around 30% will only make this problem worse. Knebworth needs some official car parking areas, not new housing, but I imagine that there would be less money in that for the landowners.

Knebworth is in a slight physical valley and some parts of it have flooded on recent years with heavy rainfall. One area proposed for the new houses hosts lagoons to contain excessive water flow from the A1M. More "hard", surfaces in this area will speed up the movement of water to the village. On a wider point the new developments proposed at the sites KB1, KB2 and KB4 are all in areas around the edge of the village where surface water would naturally disperse. The proposed use of this land for housing will remove this and add further concrete/tarmac, placing more pressure on the existing drainage system. On the same topic, I believe that the sewage treatment infrastructure will need to have significant modification to support these new dwellings and the other additions on the route to the facility.

Although a junior school is planned for inclusion at the KB4 site I can see no other industry being attracted/planned for. This means no new source of employment and that all the people who come to Knebworth are expected to work somewhere else. The addition of so many new residents without any new form of employment will hasten the demise of the village by making it a dormitory town. This should not happen; it will accelerate the change of the character of the village.

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.

Ref: Local Plan 2011 - 2013 Paragraphs 13.183 - 13.202
I would have liked to have filled in in your application form online but I had real trouble actually typing in the boxes. Most of the text was cut in half or the boxes disappeared when I tried to type. So please accept this email as my application.
According to the CPRE newsletter, Spring 2016, page 1, "Hertfordshire is currently the worst affected county in terms of potential loss of Green Belt to development. Over 41,000 new homes. The size of Watford."
In August 2013, the planning application for 3.600 new homes, west of Stevenage, was withdrawn as not required and in the wake of BREXIT, immigration is to be reduced. If either or both of these states are true do we still need so many new homes? Is this Local Plan already out of date?
I wish to draw your attention to the proposed housing development for the village of Knebworth. The Local Plan acknowledges the fact that Knebworth is a village describing it as a Category A village because of its size, employment availability and facilities. 663 new homes will increase the size of Knebworth by 31%. As I understand it, this is the largest percentage increase planned for any other town or village in Hertfordshire. It will change the character of the village completely. This increase will impact on the existing services and infrastructure that are already struggling to cope. This proposed development does not take into account the approved plans for 80 new homes on the northern border of the Knebworth parish, adjacent to Stevenage.
There is no strategy included in the Local Plan to make the planners and construction teams for all the site to work together for the bettering of infrastructure and transport opportunities.
I suggest that the NHDC planning department ensures that all empty properties are occupied before allowing the proposed development to take place eg. House in Gun Road, Knebworth that has never been occupied in over 20 years. (see attached photos)
The infrastructure for Knebworth is already woefully inadequate. Twice recently there has been bad flooding forcing people to leave their homes. There are pinch points in Watton Road (access to KB4), the high street (B197), three narrow rail bridges with height or weight restrictions and blind bends (access to KB2 & KB3) which all cause congestion and road rage. The station, doctors' surgery and the primary school are also struggling to cope.

TRANSPORT
GOVIA, the local rail operatives are reviewing the possibility of reducing the rail service at Knebworth. With increased housing both within Knebworth and surrounding villages e.g. Codicote, Woolmer Green, even more pressure will be put on the station and its environs.
The railway station in Knebworth has inadequate parking facilities but still draws commuters from surrounding towns and villages, as they park on the streets near the station, thus avoiding parking fees. However the problems have never been resolved and residents regularly have to put up with commuter aggression and dreadful parking across their driveways so that they can't use their own vehicles. This leads to residents parking their own cars on the road to stop the inconsiderate parking from the commuters, thus increasing congestion and road rage.
To compound the daily misery of Knebworth commuters, GOVIA, the current franchise holders of the London to Edinburgh line, is reviewing the timetable with the view of reducing the number of trains that will stop at Knebworth and stopping the fast trains altogether This mitigates one of the reasons for increasing housing in Knebworth.
The residents of Knebworth experience daily congestion on the B197, especially but not only at peak times, making tail backs from Knebworth to Stevenage and from Knebworth to the Clock roundabout at Welwyn.
The A1M motorway was originally built as a bypass to Knebworth and other communities. The stretch of motorway from J6 -7 is the worst along the whole of the A1M for accidents and congestion, due to two lane carriageways. This means that, as soon as there is a problem on the motorway (high volume, accidents etc.), the B197, through Knebworth becomes the bypass for the A1M. With increased housing this only become worse.
FLOODING
The field identified for the KB2 housing project is a designated surface water run off for the A1M motorway. Recently this water has been so deep that it went up the thighs of one person in waders (see attached photos) and has flooded homes in Orchard Way and Broom Grove, so there has been an inquiry into this problem. The new houses will exacerbate this problem.
In addition, the Rye Meads Sewage Plant, which acts for Knebworth is already at full capacity. So where will it all go?
AFFORDABLE HOUSING
Although affordable housing would be an ideal dream, it has not proved to be a reality in Knebworth. Developers always state that affordable homes are not viable. In addition the affordable home provision was reduced in the Housing and Planning Act 2016.
GREEN BELT
As stated at the beginning of this letter Hertfordshire is currently the worst affected county in terms of potential loss of Green Belt. Green Belt was instigated to prevent the coalescence of communities. As such, Green Belt land should only be removed in exceptional circumstances. This proposed housing does not constitute 'exceptional circumstances'. (http://planningguidance.communities.gov.uk/blog/policy/achieving-sustainable-development/delivering-sustainable-development/9-protecting-green-belt-land/)

CONSERVATION
There are two main conservation areas within Knebworth. These are already suffering as rat runs with the aim of trying to avoid Knebworth's congestion as well as suffering from commuter parking.
One of the three bridges is a scheduled ancient monument (KB1). This bridge is already taking a regular hammering from all kinds of traffic that use it as a cut through or following satnavs. Lorries have been see to be reversing back off this bridge onto the B197 as they can't negotiate the tight bends or are over the weight limit.
COALESCENCE
The sites highlighted for new homes, especially KB2 and KB4 will cause coalescence between Stevenage, Knebworth, Woolmer Green and Welwyn making the B197 a built up ribbon development corridor.
Green Belt land was originally designed to prevent communities from coalescing. The railway line that delineates the border between Knebworth and Stevenage has already been breached as planning has been granted for 80 new homes on the Knebworth side of the track.

KB1 and KB2
As stated under FLOODING this land is a collection point for surface run off water from fields and the A1M motorway. (see attached photos)
All new residential traffic will have to join the already heavy traffic using the conservation area of Stockens Green, culminating in trying to cross the railway by using the bridge to Gun Road. This bridge is narrow making traffic drive in the middle, and a blind spot to traffic coming from KB2, as there is a right angled bend into the bridge. Added to this, during winter months, drivers also have to contend with driving into low blinding winter sun. The bridge is only 14 feet high which will cause problems for construction traffic. (see attached photos)
Traffic could also use the bridge at Deards End Lane, which has a blind bend at both ends and is a scheduled ancient monument or the bridge in Station Road. The latter bridge has been hit so many times by lorries that there are now very large fluorescent signs warning lorry drivers about how low it is.
Due to the design of all three bridges, traffic is forced to use the middle of the road, making for single lane traffic, when either crossing the Deards End Lane bridge or going through the Gun Road and Station Road bridges.
KB3
This site is, at the moment, the site of Knebworth's principle employer. Soon this builders' yard will be closed, making jobs redundant, and will be replace with 14 new homes. This is prime commercial land that is being changed to housing. One of the major statements within the NHDC proposal was the maintenance and expansion of local businesses. Not only is there a loss of a commercial site in the centre of the village there are already issues with bottle necking traffic. Also surface water drainage is a problem on the high street.
In addition to losing these jobs, the doctors' surgery is to be amalgamated with the library on the library site. The library is to be downgraded to Tier 3, which means it will be run by volunteers only. A pharmacy is to be included. As we have two pharmacies on the High Street now, with a third proposed in the surgery, it is quite likely that at least one, if not both of the street pharmacies will close. So along with paid library staff, pharmacy employees may also lose their jobs. CPRE states that no evidence has been put forward to show that new employment opportunities have been established in the village to match the amount of proposed housing. We are losing employment opportunities and facilities at a time when they should not only be kept, but increased and developed if the new housing goes ahead.
KB4
The National Planning Policy Framework (NPPF) principle states "the intrinsic character and beauty of the countryside should be recognised while supporting thriving communities". This has clearly not been considered during the construction of the NHDC Local Plan. It also says planning should ensure the protection of the countryside and agricultural land.
CPRE Newsletter Spring 2015 states, " Planning Authorities' duty is to give weight to the protection of the best and most versatile agricultural land". This is prime agricultural land. Planning permission was withdrawn in 2016, by the Secretary of State, for a solar farm, due to the high quality agricultural land and the outstanding beauty of the area.
During drop off / pick up times it is dangerous for carers and the children outside the local primary school, due to carers parking on bends in narrow Swangley's Lane. This has been highlighted by a local resident at a Parish Council meeting as an accident waiting to happen. Increased residential traffic, and prior to that, builders' traffic will only exacerbate the problem and the danger.
KB4 will bring coalescence between Stevenage and Knebworth at the Broadwater side of Stevenage and also, potentially, with Woolmer Green, where addition housing is planned by Welwyn Hatfield District Council but not accounted for by NHDC under the proposed housing for Knebworth.
To sum up, I appreciate that more housing is needed but the proposed developments appear to be a knee jerk reaction and not carefully thought through, not just for the existing residents but for the people who will move into Knebworth as a result of the increased housing available. Knebworth is a sought after village enjoyed by many, but this will be killed if the proposed housing goes ahead on such a grand scale.
In August 2013, planning approval was withdrawn for 3.600 new homes on land west of Stevenage, as the need was not there anymore.
When land is built on, it's lost to agriculture for ever. If we, as a nation, should need to feed ourselves without importation (eg. during a war) we will not have enough agricultural land available.

Many thanks for taking the time to read my thoughts, comments and concerns.

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.

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I wish to register my complete objection to North Herts District Council proposed plans for the development to expand areas of Knebworth Village. The reasons for my objection as follows: -

1. Under this proposed plan it is clear that no consideration has been given to the impact it will have on the, already overstretched, local infrastructure.

2. The traffic flowing through, or trying to negotiate passing through Knebworth village, is horrendous at the best of times and mostly at a standstill, particularly on the B197 which is the main route through the village. Car parking, even for residents, is practically impossible and is exasperated by non-resident car owners parking their vehicles (where ever they feel fit) in order to use the local railway station for their daily to commute to work in London, Peterborough or Cambridge.

3. I myself have had occasion where inconsiderate drivers have parked in front of my property, for the whole day, preventing me from exiting my own driveway until they return in the evening. This type of situation (which is very common through-out the village) is intolerable and will only get worse if this planned development goes ahead. This plan simply does not provide for the current local resident's needs in anyway what so ever.

4. This proposed local plan lacks any form of strategy for Knebworth and cannot be deemed justified or fair in anyway in-so much as the forecast development proposed for Knebworth is much, much higher than other areas in North Hertfordshire. Furthermore the is no connection between the proposed extra housing, cumulative development and infrastructure needed to support the growth sustainably.

5. There are ample "Brown Field" and empty sites with-in North Hertfordshire that could be utilized to accommodate such additional housing/dwellings projects in the region, without the need of having to build on and remove designated Green Belt space between towns and villages in the district. The old Kodak site at Caxton way Stevenage is a prime example of such wasted acreage and unused wasteland.

6. National government policy states it will protect the Green Belt and Green Belt buffer zones, yet this local plan proposes the complete opposite by identifying three large areas to the east and west of Knebworth. Furthermore the proposed sites at KB1 & KB2 to the west of Knebworth are designated conservation areas. What is the point of having a National protection policy if it's not to be maintained?

7. The areas being consider for development KB1, KB2 and KB4 are prime productive Agricultural land which, if lost, will have an impact on wildlife sites of special scientific interest and will result in additional traffic congestion on narrow roads, unsuitable for heavy traffic and usage, not to mention the additional surface water and flooding problems.

8. The local primary school in the centre of the village is completely over-subscribed, mainly by the children of families that do not live in the village, and whilst the proposed plan has provision for new schooling, it is totally inadequate and does not take into consideration any future needs for access to secondary education and schooling.

9. There is absolutely no provision or consideration in this plan to address the impact such an additional influx would have on the already oversubscribed current medical practice and services.

10. The local Doctors surgery, at the centre of the village, is not fit for purpose and cannot cope with its current registered patients and ever growing elderly population, let alone and additional influx of families and their needs. As a patient of the practice I know by experience that it is near on impossible to secure an appointment to see your own local doctor and trying to do so often results in being offloaded to their sister surgery in Marymead, Stevenage - which is equally over-subscribed and at capacity.

11. There is no provision in the plan for the creation of any new (local) employment opportunities, potentially resulting in extra strains on the local unemployment and social services/benefits offices. Where and how are these new families going to be able to secure gainful employment when, as a district, North Herts already fairs poorly?

12. There is no provision in the plan to tackle the additional congestion on the roads and railway station during peak periods. The limited car parking spaces available are already at capacity, which often leads to double or illegal parking and the main train station struggles to cope as it is.

I have been resident in Knebworth village for the last 30 years, during which time I have witnessed the whole of the village (and surrounding areas) slowly grind to a halt. Should this plan go ahead as proposed, it is likely going to kill off all of what is left.

I trust my, and other concerned residents of Knebworth views will be seriously considered and that these proposals will be rejected as they are ill thought out and not feasible or sustainable.

Although I accept that more (affordable) housing is needed in North Herts, that
there are not enough brownfield sites to meet the targets NHDC has been given,
and that in effect NHDC is caught between a rock and a hard place, I am objecting
to the NHDC Local Plan for Knebworth (paragraphs 13.183-13.202) because it is
unsound. My reasons are the following:
1. It is not positively prepared because:
* NHDC conducted a preliminary consultation, but despite record numbers of
people attending public meetings and responding in writing, NHDC have not
addressed the community's areas of concern. Nor have they modified their
proposals for Knebworth in line with the community's objections - in fact, they
have actually increased the housing provision by 50%. Therefore, NHDC have not
engaged adequately with local residents.
* The proposal to build a minimum of 663 dwellings in Knebworth by 2031would
increase the number of houses in the village by a massive 31%, which would have
an overwhelmingly detrimental effect upon Knebworth's character, traffic,
infrastructure and Green Belt.
* The only access to the proposed homes on the western edge of Knebworth
would be via Gypsy Lane or Deards End Lane, which are narrow country lanes with
blind bends and no pedestrian paths. They are already heavily used as rat runs and
are notoriously dangerous for drivers and pedestrians alike. They could not sustain
the traffic associated with a 31% increase in population.
* Watton Road, St Martin's Lane (much of which is private), and Swangley's Lane
could not take the increased traffic from 200 homes built to the east of
Knebworth (site KB4). Watton Road in particular, which runs between the B197
and the A602, is already a major bottleneck in the village.
* The B197 running from Welwyn to Stevenage is often clogged with bumper-tobumper
traffic during the extended rush hours (even when there are no problems
on the A1(M), for which the B197 has become an overflow road) and would come
to a standstill with the large increase in traffic. Solving the notorious parking
problems in Knebworth High Street would not solve the problem, as it is caused
mainly by the sheer volume of traffic. The plan does not identify any specific
traffic-mitigation plans.
* The only access from the town centre to the proposed dwellings on the western
edge of Knebworth is under one of two railway bridges (in Station Road and Gun
Lane), which are each so narrow that there is not room for two cars abreast, and
where there is only a very narrow pedestrian pavement, causing people (especially
children) to step into the road when passing another pedestrian. There is an
electricity sub-station alongside each bridge which could hamper any attempts by
Network Rail to widen the road under each bridge (even assuming Network Rail
were willing to attempt any widening, which is unlikely).
* Trains running from Knebworth station are used not just by residents of
Knebworth but also by those from the surrounding villages, resulting in
overcrowded carriages and inadequate parking in the village. The station car park
is small and usually full, so commuters' cars are parked in the roads, creating
traffic hazards particularly in Park Lane, Gun Lane, Lytton Fields and Deards Wood.
These would only be exacerbated by a 31% increase in the village's population.
* The plan does not take into account the local infrastructure, which is inadequate
for such a large increase in population. As well as the transport problems (see
previous five points), the doctors' surgery is struggling to cope with the existing
population. In addition, there is only one primary school in Knebworth, which takes
60 pupils a year and is always oversubscribed, and there is no secondary school.
None of these could cope unless they were substantially enlarged.
* The plan makes no provision for a secondary school; it does claim that a primary
school could be built on site KB2/Gypsy Lane, but there is no actual provision for
it. In fact, its proximity to the A1(M) would mean that children - who are
especially vulnerable to black carbon, nitrogen dioxide and particulates, which
stunt their lung growth and brain development and cause asthma - would be
subjected to severe air pollution at the proposed school.
* The plan is unsustainable because the close proximity of the A1(M) would cause
irreversible damage to the well-being of future generations, not only in relation to
the proposed primary school (see previous point) but also because of its being the
site for two-thirds of the total number of houses proposed for Knebworth. The
184+ houses on site KB1/Deards End Lane would be less than 500m from the
A1(M) and the 200+ houses on site KB2/Gypsy Lane would be less than 250m
from the A1(M); at one end, the outer boundary of site KB2 is only about 100m
from the A1(M). This motorway is a pollution hotspot, meaning that the expected
life span of people living in the houses would be reduced. Noise pollution would
also be an issue for residents of these houses.
* The plan does not take into account the county's own plans for widening the
A1(M) between junctions 6 (Welwyn) and 7 (Stevenage) by one lane northbound
and one lane southbound. This is listed by herts.gov.uk as a medium-term scheme
and would surely drastically affect the proposed sites KB1/Deards End Lane and
KB2/Gypsy Lane, in terms of both land available and proximity to air pollution.
* There are drainage issues relating to the KB2/Gypsy Lane site. Parts of
Knebworth (including Broom Grove, Orchard Way, Gipsy Lane and site KB2 itself)
have been subject to localised flooding in the recent past, caused by surfacewater
drainage problems, an overflowing lagoon alongside the A1(M), and runoff
from this motorway, and these problems have still not been solved by NHDC.
Paving over the fields of sites KB1 and KB2 would exacerbate this problem. There
is also an acknowledged capacity issue at Thames Water's Rye Meads Sewage
Treatment Works, which treats Knebworth's and Stevenage's sewage.
* The proposals would remove 46.7 hectares of agricultural land, which is
important for wildlife and local residents' use, as well as agriculture. The impact on
Knebworth's setting in open countryside would be substantial and damaging.
* There is no guarantee in the plan that the majority of the proposed homes
would be social and affordable housing rather than the more expensive 'executive
homes' that developers prefer to build. Likewise, there is no guarantee that the
minimum number of houses would not be exceeded, creating an area of dense
housing that would be incompatible with the leafiness and rural nature of the
surroundings.
2. It is unjustified because:
* NHDC has not properly examined the possibility of building a proper 'garden
community' instead of drastically expanding Knebworth and other villages. In
addition, there are undoubtedly more brownfield sites that could be utilised.
Because of pressure to complete the plan by the deadline, NHDC, rather than
choosing the most appropriate strategy for Knebworth, has simply chosen the
easiest option - to use land from just two sources, both of which are eager to sell.
Because it is nearly all big chunks of Green Belt land rather than numerous small
brownfield sites, the land is cheaper to develop and therefore more attractive to
developers.
* The NPPF states that the Local Plan must identify a five-year supply of specific,
deliverable building sites, but the NHDC plan covers 20 years (2011-2031) rather
than five. Furthermore, NHDC has chosen an arbitrary housing target over the 20-
year period, designed to compensate for the unmet housing requirement
elsewhere, particularly in west Luton - this is indefensible and unnecessary.
* Ten years ago NHDC decided that 'Knebworth is not suitable for further
development as it would risk the sustainability of the village'. Now NHDC has
reversed their stance and recommended a housing target that is higher than
elsewhere in North Herts. This is unjustified and will have a disproportionate
impact on Knebworth, as NHDC's 2006 study foresaw.
* The plan for Knebworth does not take account of the impact of the Local Plan's
proposal for 150 new houses in the adjacent small village of Woolmer Green, the
population of which uses Knebworth facilities.
* There is no provision for additional employment in Knebworth; in fact, it reduces
employment by earmarking site KB3/Chas Lowe's, which has been commercial
premises, as residential development.
3. It is ineffective because:
* The number of houses the plan proposes would be impossible to achieve during
the designated time periods, particularly the final phase. There are not enough
builders to actually do the work within the time frame, given that they will be in
demand all over the county and indeed the country. Nor would there be time to
alter the infrastructure sufficiently to support a 31% increase in the population.
* The proposed Local Plan will not deliver a sustainable plan for Knebworth
because of the problems associated with overwhelming demands on the local
school and doctors' surgery, and with parking, traffic congestion, A1(M)-widening,
air pollution, drainage, and loss of Green Belt land that surrounds the village and
protects it from merging with Stevenage and nearby villages. The plan is
unrealistic and unattainable.
4. It is inconsistent with national policy because:
* NHDC has proposed that 46.7 hectares of land be built on, of which 99 per cent
is Green Belt. Yet the NPPF stipulates that Green Belt land should only be used
under 'exceptional circumstances'. These are not exceptional circumstances. The
Green Belt around Knebworth is vital to help retain its rural nature. Earlier in 2016,
the Dept for Communities and Local Government said, 'Ministers have repeatedly
been clear that demand for housing alone will not justify changing Green Belt
boundaries. Councils are already expected to prioritise development on brownfield
sites.' Furthermore, the local government secretary has recently said that the
Green Belt is 'absolutely sacrosanct'.
* The national policy is to try to keep villages' own identities and prevent them
from coalescing into one sprawling suburban conglomerate. The proposed
development of Green Belt land on the east side of Knebworth (site KB4) would
take the boundaries closer to Stevenage and to Datchworth, while Woolmer
Green's Local Plan would bring it closer to Knebworth.
* Government planning policy states that any development must be sustainable
with the current or planning infrastructure, but the proposed plan does not take
Knebworth's infrastructure inadequacies into account.
* The Air Pollution Minister for the Dept for Environment, Food and Rural Affairs
has said that the government has committed to cutting air pollution to which
people are subjected, yet the Knebworth plan proposes that 384+ houses and a
primary school be built right next to a pollution hotspot, the A1(M).
* Government policy is to preserve the unique character of conservation areas.
Yet 59% of the proposed building land, containing two-thirds of the proposed
homes, is adjacent to one of Knebworth's two conservation areas - Stockens
Green conservation area and Deards End Lane conservation area - upon both of
which this development would have a seriously detrimental effect.

We are writing to express our concern about the Local Plan, which we feel is unsound. The proposed sites in Knebworth, as well as Codicote and the surrounding area, will have a detrimental impact on roads, railways, education, the environment and the character of our villages.

Knebworth surgery is already overstretched. There are plans to build a new surgery, but this is to replace the current one, it is not an additional service.

The Great Northern railway service is overcrowded at peak times and even off peak there is often standing room only. Parking at Knebworth Station is totally inadequate.

The B197 through Knebworth and the B656 through Codicote take a lot of commuter traffic from adjoining villages which converges at Old Welwyn to join the A1M. At peak times, all these roads become congested, even gridlocked. When the A1M, M1 or M25 have closures the extra traffic converges on our local roads bringing everything to a standstill. The impact of extra housing and therefore more vehicles will be catastrophic.

Contrary to the Department of Transport's guidelines Sites KB1 and KB2 in particular are unacceptably close to the AlM, potentially causing unpleasant and unacceptable environmental conditions for residents.

We feel that the Council has not demonstrated 'exceptional circumstances' for removing land from the Green Belt. Green Belt land offers significant protection of the space between villages and towns in the district enabling Knebworth to keep a separate identity.

The Local Plan is inadequately prepared and, if the proposed housing goes ahead, the character of Knebworth and the surrounding villages will be changed irrevocably. A new garden city, as has been suggested by our MP Stephen McPartland, would seem to be an excellent solution to the district's housing dilemma.

The local infrastructure needs have certainly not been considered to absorb all these extra houses.
There is one road the B197 which stretches from junction 6 of the A1M passing through Mardley Hill, Woolmer Green, Knebworth through to Stevenage.
When there are any problems on the A1M - which is generally two or three times a week - motorists will use the B197 which causes tail-back problems and often gridlock in Knebworth village centre.
In the morning rush hours it has taken me 45 minutes to get from Knebworth to junction 6 of the A1M which is only about 4 miles even before any extra traffic from the proposed developments.
In Knebworth access to the west side planned development (KB1 and KB2 , 200 dwellings, 184 dwellings plus primary school) is by 2 narrow low railway bridges. There is also access in Woolmer Green by a narrow low railway bridge. A
few years ago an application for a senior school in Woolmer Green on the field by this railway bridge was turned down one of the main reasons being lack of proper access. Why is access not considered a problem in this instance?
The bridges are too narrow and in Knebworth have blind bends leading up to them. There is also only a narrow path down one side and the road is single track. Pedestrians have to walk in the road when passing each other, especially when
pushchairs are involved. A friend of mine was actually hit on the hand by a car while walking under the bridge which she reported to the police. How can these bridges sustain yet more traffic?
Access to Knebworth can also be made from the B197 from Mardley Hill at Canonsfield Road which then turns into mostly single track lane - Pottersheath Road, Spinney Lane, Wych Elm Lane and finally Gipsy Lane. More traffic will
obviously use this way as a short-cut. More delivery vans, lorries and cars making it very dangerous for pedestrians (no pavements) and cyclists.
Also each Spring there are toads which migrate from one side of Spinney Lane to the other and homemade notices are put out warning motorists to slow down and look out for them. With the increased traffic I certainly fear for the
toads!
Green Belt Removal
The Green Belt land on the KB1 and KB2 sites is a buffer between Gipsy Lane and the A1M and it is a fact that the A1M at this point creates the most pollution due to the motorway merging from three to two lanes thus causing slow traffic every day especially in rush hours.
Also the Green Belt protects the space between Knebworth, Woolmer Green and Stevenage protecting its identity as a village which the residents regard as very important. Green Belt protection is national policy yet the Local Plan is
proposing to remove large areas. Surely the law was introduced to protect exactly these issues so how can it be dismissed so easily and what protection does any Green Belt have in the future?
Also important productive agricultural land will be lost for ever and how is this acceptable.
There is no consideration for the local economy. A key commercial site in the village (KB3) is going but instead of building a mixed use replacement only flats are being
planned.
An incease of at least 663 dwellings in Knebworth between 2011 and 2031 is an increase to the village of 31% which is completely unsustainable with no added infrastructure.
Even the railway station does not have adequate parking creating more congestion in the side roads and the plan from Thameslink is to reduce the fast trains into Kings Cross, not to increase them.
The extra impact of a planned 150 homes in Woolmer Green also appears not to have been considered.
The alternative in my view is the Stevenage West land which is reserved for 3,100 - why has this not been mentioned/considered??

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I refer to the Proposed Submission, Paragraphs Knebworth 13.183 - 13.202 of the local plan
and would refer to your References KB1, KB2 and KB4 in particular.

Apologies for not completing this on line but a glitch is not allowing me to do so...
However...

I wish to strongly object to the entire "plan" on the following grounds.

I have lived in Knebworth since buying my house in December, 1986. My parents lived in Knebworth from 1975 and my sister and her family, even longer.
We moved from St Albans, .. to be in the country.

This "Plan" (sic) takes absolutely no account of the following:

1 No plans to substantially, improve the basic infrastructure.
Access roads are already under heavy pressure from traffic for school runs, basic shopping needs and, worst of all, rail commuters who park just about anywhere within the surrounding estate roads.

2 No thought or consideration to the impact on the B197 that already sees considerable congestion in the village High Street; nor the current problems with narrow single passage rail bridges, both of which will only be subjected to far more traffic.

3 Totally ignoring our Green Belt space and local Conservation area/s.

4 The SW drainage that I "only just," managed to escape, where I now live... let alone the potential overloading of the FW system which, when viewing the landscape contours will require a number of Pumping Stations.

5 I note you believe a new Primary school will be built. I wonder! And close to the already at peak times, over run with high exhaust emitting traffic on the A1 (M)

6 KB3 will see yet more commuter traffic through the High Street, assuming new residents will wish to visit Stevenage New Town, of course? Drainage here too, might prove interesting!

I'll keep it short and trust your appropriate "committee" will have a serious re-think on this extremely, poorly, thought-out "Plan."

To my mind and my entire working career was in construction from drawing board to on site management, this "Plan" is absolute rubbish.

I shall view all future "Plans" icw Knebworth and its surrounding villages (and towns) with considerable interest from here on.

Section 1:

Knebworth Estates congratulates North Hertfordshire District Council on a Plan that has - not before time - been positively prepared, and - within its delayed and limited time frame - appears justified, effective and consistent with national policy.

Section 4.9 - Policy SP2:

Knebworth Estates supports Knebworth's inclusion as a Category A village, and Old Knebworth's inclusion as a Category B village - although it argues that there are sometimes cases where it is preferable for a village to evolve outside of its "built environment" rather than on the open and green spaces within its "built environment", and that the Plan should allow for such cases.

Section 4.37 - Policy SP4:

Knebworth Estates supports the Plan's commitment to protecting the vitality and viability of the range of retail facilities in the local centre of Knebworth.

Section 4.127:

Knebworth Estates supports the Plan's commitment to deliver appropriate primary and secondary school facilities for Knebworth.

Section 4.162:

Knebworth Estates supports the Plan's commitment "to find new, appropriate uses and solutions to secure the future of heritage assets."

Section 4.165:

Knebworth Estates does not support the Plan considering serving Tree Preservation Orders within historic parks and gardens as this could run contrary to the Plan's commitments in Section 4.162 and the management of historic parks and gardens - and the preservation of, interpretation of, and access to, the heritage assets within - are unlikely to be any better served than by those to whom it is a day-in-day-out commitment and responsibility. Knebworth Park and Gardens has its own Historic England approved Conservation Plan and an exemplary record in its heritage management, and yet another level of statutory requirement is unjustified, unnecessary and counter-productive.

Section 5.28 & 5.29:

Knebworth Estates supports the Plan's intent that Knebworth village centre should continue to provide a mix of shopping, services and community facilities.

Sections 5.39 to 5.48 and Policy ETC8:

Knebworth Estates supports the Plan's commitment to Tourism and argues that - whilst being an Historic England "Priority Building At Risk" - Knebworth House and Knebworth Park belie Section 5.41's statement that North Hertfordshire is not a major tourist destination. The Visit Herts DMO, VisitEngland, the LEP, and Hertfordshire County Council all recognise the district's strong tourism draw and impact. Knebworth House is one of only two Historic Houses in Hertfordshire with a national profile (the other being Hatfield House in the Welwyn and Hatfield district) and Knebworth Park is unique nationally in its capacity for large music events. The Plan should be aspirational to the benefits and potential of Tourism.

Section 6:

Knebworth Estates broadly supports the Plan's Green Belt policies - although, as in Section 4.9, Policy SP2 above - it argues that there are sometimes cases where it is preferable for communities to evolve outside of the "built environment" rather than threatening the quality of life, open and green spaces, balanced zoning and heritage of the "built environment". Knebworth Estates supports the consideration of "exceptional circumstances" within Green Belt policy.

Section 12 - Policy HE2:

Knebworth Estates supports the Plan's "Heritage at risk" policy.

Section 13.183 to 13.202 - Knebworth:

Knebworth Estates supports the Plan's policy for Knebworth within the context and scope of the Plan's objectives and time scales.

Ref - Knebworth - KB1 & KB2:

Knebworth Estates supports the Plan's Housing Allocation and site specific criteria for KB1 and KB2:

Commitment

As freehold owners of the sites identified as KB1 and KB2, Knebworth Estates reiterates its commitment, as expressed in previous consultation responses - and in consultation responses of the independent charity representing Knebworth House (The Knebworth House Education and Preservation Trust), to which Knebworth Estates is primary donor - that if these sites are brought forward for residential designation, it will move swiftly to work with the Council to deliver the full required housing targets with maximum sensitivity to the community of which it has been a part for over 500 years.

Proof of this commitment is to be found in the Estate's long record of involvement in the evolution of the community of Knebworth - since the settlement's beginnings - and specifically, in its multi-generational quest to restore and protect Knebworth House, its Park and curtilage, for public benefit and access (see "Opportunity" below).

The Estate treasures Knebworth's green spaces and environment - it has been a long term guardian of these - however it also believes that Knebworth should play its part in contributing to housing need identified in the Plan, and in the planned evolution of the District as conceived in the Plan. It recognises, with the Plan, Knebworth's pre-existing infrastructure - "a good range of facilities including a railway station, school, doctors and dentists, library, a range of shops, village hall and churches" - and thus considers it right that Knebworth shares responsibility to provide for residential growth with other communities in the District.

As part of Local Plan residential growth, the Estate supports the provision of affordable housing and schemes to provide homes for those who have grown up in the community. It recognises that new homes generate extra pressure on schools and supports increasing school provision. Increased school provision will strengthen Knebworth's independence of Stevenage and other growing towns, promote community spirit - a deficiency identified in the Knebworth Parish Plan (April 2007) - and ease pressure on road and rail networks at peak times.

Delivery

The Estate recognises the extensive evidence base compiled by the Council to support the suitability of sites KB1 and KB2 and looks forward to working with the Council, the community, neighbouring landowners and future development partners to conduct further studies to confirm and expand on this evidence, which it believes to be sound.

The Estate is pleased to have already contributed to existing evidence with input into Knebworth Parish Council's Knebworth Parish Plan (April 2007 - http://www.knebworthparishcouncil.gov.uk/uploads/knebworth-parishplan-1sted-web.pdf) and Knebworth Sites Appraisal Report (December 2007 - http://www.knebworthoptionsreport.org/).

Sustainability

The Estate recognises the Council's Capacity and Sensitivity Studies of 2006, and - as part of the community, and its owners resident within the community - is particularly sensitive to the issues raised by those who oppose development on these sites. It has listened to, recorded, and considered the practical concerns of its neighbours - through previous consultations, involvement in the Knebworth Parish Plan (April 2007) and the Village Appraisals of 1996 and 2007, and at a number of public meetings over the years - and is confident there are practical solutions and mitigations to the issues raised.

The Estate would seek - in working with the Council, any development partners and its neighbouring landowners - to work with Knebworth's new Neighbourhood Plan to promote a balance of achieving the Local Plan's targets, addressing sustainability and infrastructure issues and concerns, and fulfilling community aspirations. Within the parameters of the Plan, it would look to development in keeping with - and improving on - Knebworth's existing Conservation Areas and Edwin Lutyens' original 1910 framework for "Knebworth Garden Village".

Opportunity

Reinforcing the Estate's commitment, and adding to the opportunity of facility and infrastructure improvement in the wider community, is one factor that is unique to Knebworth Estates. Reflecting the intent of the Plan in Policy SP13a - "Maintaining a strong presumption in favour of the retention, preservation and enhancement of heritage assets and their setting" - the Local Plan's requirement of Estate sites for residential provision would present a once-in-a-generation opportunity to solve the Estate's multi-generational quest to endow the Knebworth House Education and Preservation Trust, a charity created in 1984 for the preservation and enhancement of the heritage asset of Knebworth House and its setting.

Residential designation of KB1 and KB2 would result in sufficient funding for this charity to halt the decay of Knebworth House - an Historic England designated "Priority Building At Risk" - complete its half-finished programme of urgent restoration, and secure an endowment for its future survival, and continued and expanded public access and interpretation.

The Knebworth House charity's record over its 33 year history, its established "exceptional circumstances", its Conservation Plan as submitted to North Hertfordshire District Council in July 2001 - and the Estate's record in endowing, and seeking to complete that endowment - is evidence of the commitment of the Estate and the Charity.

The collateral opportunity presented by the designation of KB1 and KB2 within the Local Plan therefore extends beyond the crucial issue of local residential shortfall, to address also major issues of benefit to the whole region and the nation beyond.

Ref - Knebworth - KB4:

Knebworth Estates supports the Plan's Housing Allocation for KB4. Whilst comfortable that KB1 and KB2 could be successfully delivered without KB4, Knebworth Estates expresses its support for KB4. The Estate enjoys a close and mutually supportive relationship with the landowners of KB4 and, in the event that both landowners have sites proposed for development in the final Plan, we would look to work closely with each other to take an holistic view of Knebworth village and, together, maximise infrastructure advantages for the greater benefit of the wider village and its long-term future.

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This plan is completely lacking in coherent strategy, and is not positively prepared. The plan fails to connect housing growth to infrastructure development to support sustainable growth. This plan for a 31% increase in dwellings in Knebworth will cause significant transportation issues, coalescence with adjacent settlements and the only infrastructure investment is for a Primary school located next to a motorway!

The original draft of this proposal included approximately 200 fewer homes and met with strong local opposition and legitimate concerns. There is no evidence of any of these concerns (particularly with regards to transport) being addressed in the latest draft, which then added the new sites at KB4 to the east of Knebworth. There has been no local consultation on the site at KB4 which I understand is contrary to national guidance.

The plan is not positively prepared because it circumvents planning policy that developments >500 homes should have their own specific plan. Adjacent sites at KB1 and KB2 are effectively the same development.

The only infrastructure mandated development mandated in this proposal is for an additional Primary School, close to the A1M. This would be adjacent to the A1 and as such noise and air pollution will be significant. 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.'

The housing in Knebworth is not justified because it makes no consideration of Planning granted for the Odyssey site to the north of Knebworth for approx. 70-100 homes. A clear strategy should take these into account, instead of terming these 'windfall' gains.

The plan is not justified because Stevenage West land has already been reserved for 3,100 homes. This would be better able to provide facilities and services.

The plan is not effective because 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. Significant risk of coalescence

Chas Lowe site: This proposal contradicts the retail policy for Knebworth that states development of commercial property should be for mixed used, residential and commercial. 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

Green Belt:
Green Belt land makes a significant contribution to protecting spaces between towns and maintaining the separate identity of Knebworth as a village. Development of sites KB1 and KB2 will remove the Green Belt buffer between the village and the A1. There will be a loss of countryside and the open landscape setting.
Drainage issues:
Drainage issues have been raised time and time again. There will be a major capacity issue at Rye Meads Sewage Treatment Works and this has not been addressed. Surface water is already a problem; this will be exacerbated with increased population and households.

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. It is a common occurrence for pedestrians to be "clipped" by wing mirrors of cars passing under the bridges. 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).
Deard's 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:

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. It would be naïve to assume that parents would automatically chose the primary school nearest to them, or on their side of the village

The plan is not positive prepared because it contains significant inaccuracy with regards to secondary schools. 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.
It does not seem likely that a secondary school would be built; there is not a shortage of secondary school places in Stevenage and so there would be no reason to provide a secondary school.

Other facilities (doctors, library, pharmacy):
The Plan states that the planning permission has already been granted for a new doctor's surgery and library. This is true, but this is to REPLACE the current doctor's surgery and library; this did not take into account additional population. Therefore, the services provided will not meet the requirements of a village increased by 31% (number of homes).

Development of sites KB1, KB2 and KB4 around Knebworth directly contradicts North Herts Green Belt Review 2016. This strategic review of Green Belt in North Herts identified these areas as most significant in safeguarding the countryside from encroachment; significant in preventing neighbouring towns from merging into one another, and significant in their overall contribution to Green Belt purposes.
Knebworth is unique in North Herts as it borders on Stevenage Borough, East Herts District and Welwyn Hatfield Borough. It is incumbent upon North Herts Council to reject development in this area.

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

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