KB3 Chas Lowe site, London Road

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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.

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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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).

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Please see the attached submissions.

KB1 Land at Deards End Lane
Deards End Lane is a busy access point into Knebworth from Stevenage and is used to access the west side of Knebworth without travelling along the B197 through the often congested high street. Deards End Lane is a single track road for most of its length with some passing points and many blind corners make it dangerous to drive and especially for pedestrians. At its junction with the B197 there is a bridge, over the railway. This bridge is weight limited and narrow allowing only single lane traffic. The proposed development on the KB1 site will cause increased traffic on this already congested and dangerous route.
An alternative route through Knebworth to the KB1 site is via the bridge, under the railway, on Station Road/Station Approach, which is height restricted is too narrow for traffic to travel in both directions, and subsequently does not even have road markings down the middle of the road.
Both of the above routes terminate at the B197 which suffers from traffic congestion due the weight of traffic using it. Another contributor to this is the A1M motorway running past Knebworth reduces to 2 lanes at junction 7 to the north of Stevenage through to junction 5 to the south of Knebwort/Welwyn. This stretch becomes very congested causing traffic to route through and already congested Knebworth via the B197.

KB2 Land off Gypsy Lane Lane
The KB2 site Can be accessed via multiple routes. One such route is Deards End Lane as detailed above.
There are three other main access routes through Knebworth
1. Via the bridge, under the railway, on Station Road/Station Approach, This is height restricted and does not have a white line separating traffic travelling in opposite directions as it is too narrow.
2. Via the bridge, under the railway, on Gun Lane, which is height restricted and does not have a white line separating traffic travelling in opposite directions as it is too narrow and is blind to traffic travelling from Stockens Green.
3. Via Wych Elm Lane which reaches Wolmer Green via Bridge Road. This is a single track lane for most of its length with a height restricted bridge which is too narrow for traffic to travel in both directions.
All of these routes terminate at the B197 which suffers from traffic congestion due the weight of traffic using it.

Living in Broom Grove I travel along Gypsy Lane to Park Lane daily and experience high congestion due to Gypsy lane being single track for most of its length with limited passing points.

The KB2 site is prone to surface water run off onto Gypsy lane. This causes the drains to overflow into Orchard Way and Broom Grove. This has occurred twice within the last four years to an extent that houses flooded. The concern is that development of both the KB1 and KB2 sites will cause greater surface water run off and subsequent flooding.

The development of the KB2 site conflict with national Green Belt policy (Section 9 of the NPPF).

KB4 Land East of Knebworth
There are three possible access routes through Knebworth
1. Via Watton Road which has traffic calming measures to improve road safety by restricting road width by the use of two single lane passing places.
2. Via St Martins Road which is a private road.
3. Via Swangleys Lane, the site of Knebworth Primary School, which is also narrow.
All three of these routes terminate at the B197 which suffers from traffic congestion due the weight of traffic using it.

The development of the KB4 site will risk convergence of Knebworth and Stevenage and put the identity of Knebworth as a village at risk.


The cumulative effect of all four sites (KB1, KB2, KB3 and KB4) would put a great strain on local services and facilities including roads as detailed above, health services and the Knebworth Primary School. The Knebworth Primary School is consistently oversubscribed year on year and with an intake of just 60 children per year, children living in Knebworth are often refused places. The addition of the proposed approximately 660 houses will greatly increase this demand and will be detrimental to both new residents moving into the new houses and current residents of Knebworth. The lack of a local secondary school results in high volumes of applicants to secondary schools in nearby towns Stevenage, Hitchin and Hertford from Knebworth. The proposed development will cause increased competition for secondary school places, which will again be to the detriment of both new residents moving into the new houses and current residents of Knebworth.

KB1 Land at Deards End Lane
Deards End Lane is a busy access point into Knebworth from Stevenage and is used to access the west side of Knebworth without travelling along the B197 through the often congested high street. Deards End Lane is a single track road for most of its length with some passing points and many blind corners make it dangerous to drive and especially for pedestrians. At its junction with the B197 there is a bridge, over the railway. This bridge is weight limited and narrow allowing only single lane traffic. The proposed development on the KB1 site will cause increased traffic on this already congested and dangerous route.
An alternative route through Knebworth to the KB1 site is via the bridge, under the railway, on Station Road/Station Approach, which is height restricted is too narrow for traffic to travel in both directions, and subsequently does not even have road markings down the middle of the road.
Both of the above routes terminate at the B197 which suffers from traffic congestion due the weight of traffic using it. Another contributor to this is the A1M motorway running past Knebworth reduces to 2 lanes at junction 7 to the north of Stevenage through to junction 5 to the south of Knebwort/Welwyn. This stretch becomes very congested causing traffic to route through and already congested Knebworth via the B197.

KB2 Land off Gypsy Lane Lane
The KB2 site Can be accessed via multiple routes. One such route is Deards End Lane as detailed above.
There are three other main access routes through Knebworth
1. Via the bridge, under the railway, on Station Road/Station Approach, This is height restricted and does not have a white line separating traffic travelling in opposite directions as it is too narrow.
2. Via the bridge, under the railway, on Gun Lane, which is height restricted and does not have a white line separating traffic travelling in opposite directions as it is too narrow and is blind to traffic travelling from Stockens Green.
3. Via Wych Elm Lane which reaches Wolmer Green via Bridge Road. This is a single track lane for most of its length with a height restricted bridge which is too narrow for traffic to travel in both directions.
All of these routes terminate at the B197 which suffers from traffic congestion due the weight of traffic using it.

Living in Broom Grove I travel along Gypsy Lane to Park Lane daily and experience high congestion due to Gypsy lane being single track for most of its length with limited passing points.

The KB2 site is prone to surface water run off onto Gypsy lane. This causes the drains to overflow into Orchard Way and Broom Grove. This has occurred twice within the last four years to an extent that houses flooded. The concern is that development of both the KB1 and KB2 sites will cause greater surface water run off and subsequent flooding.

The development of the KB2 site conflict with national Green Belt policy (Section 9 of the NPPF).

KB4 Land East of Knebworth
There are three possible access routes through Knebworth
1. Via Watton Road which has traffic calming measures to improve road safety by restricting road width by the use of two single lane passing places.
2. Via St Martins Road which is a private road.
3. Via Swangleys Lane, the site of Knebworth Primary School
All three of these routes terminate at the B197 which suffers from traffic congestion due the weight of traffic using it.

The development of the KB4 site will risk convergence of Knebworth and Stevenage and put the identity of Knebworth as a village at risk.


The cumulative effect of all four sites (KB1, KB2, KB3 and KB4) would put a great strain on local services and facilities including roads as detailed above, health services and the Knebworth Primary School. The Knebworth Primary School is consistently oversubscribed year on year and with an intake of just 60 children per year, children living in Knebworth are often refused places. The addition of the proposed approximately 660 houses will greatly increase this demand and will be detrimental to both new residents moving into the new houses and current residents of Knebworth. The lack of a local secondary school results in high volumes of applicants to secondary schools in nearby towns Stevenage, Hitchin and Hertford from Knebworth. The proposed development will cause increased competition for secondary school places, which will again be to the detriment of both new residents moving into the new houses and current residents of Knebworth.

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

See attached

KB1 Land at Deards End Lane
Deards End Lane is a busy access point into Knebworth from Stevenage and is used to access the west side of Knebworth without travelling along the B197 through the often congested high street. Deards End Lane is a single track road for most of its length with some passing points and many blind corners make it dangerous to drive and especially for pedestrians. At its junction with the B197 there is a bridge, over the railway. This bridge is weight limited and narrow allowing only single lane traffic. The proposed development on the KB1 site will cause increased traffic on this already congested and dangerous route.
An alternative route through Knebworth to the KB1 site is via the bridge, under the railway, on Station Road/Station Approach, which is height restricted is too narrow for traffic to travel in both directions, and subsequently does not even have road markings down the middle of the road.
Both of the above routes terminate at the B197 which suffers from traffic congestion due the weight of traffic using it. Another contributor to this is the A1M motorway running past Knebworth reduces to 2 lanes at junction 7 to the north of Stevenage through to junction 5 to the south of Knebwort/Welwyn. This stretch becomes very congested causing traffic to route through and already congested Knebworth via the B197.

KB2 Land off Gypsy Lane Lane
The KB2 site Can be accessed via multiple routes. One such route is Deards End Lane as detailed above.
There are three other main access routes through Knebworth
1. Via the bridge, under the railway, on Station Road/Station Approach, This is height restricted and does not have a white line separating traffic travelling in opposite directions as it is too narrow.
2. Via the bridge, under the railway, on Gun Lane, which is height restricted and does not have a white line separating traffic travelling in opposite directions as it is too narrow and is blind to traffic travelling from Stockens Green.
3. Via Wych Elm Lane which reaches Wolmer Green via Bridge Road. This is a single track lane for most of its length with a height restricted bridge which is too narrow for traffic to travel in both directions.
All of these routes terminate at the B197 which suffers from traffic congestion due the weight of traffic using it.

Living in Broom Grove I travel along Gypsy Lane to Park Lane daily and experience high congestion due to Gypsy lane being single track for most of its length with limited passing points.

The KB2 site is prone to surface water run off onto Gypsy lane. This causes the drains to overflow into Orchard Way and Broom Grove. This has occurred twice within the last four years to an extent that houses flooded. The concern is that development of both the KB1 and KB2 sites will cause greater surface water run off and subsequent flooding.

The development of the KB2 site conflict with national Green Belt policy (Section 9 of the NPPF).

KB4 Land East of Knebworth
There are three possible access routes through Knebworth
1. Via Watton Road which has traffic calming measures to improve road safety by restricting road width by the use of two single lane passing places.
2. Via St Martins Road which is a private road.
3. Via Swangleys Lane, the site of Knebworth Primary School
All three of these routes terminate at the B197 which suffers from traffic congestion due the weight of traffic using it.

The development of the KB4 site will risk convergence of Knebworth and Stevenage and put the identity of Knebworth as a village at risk.


The cumulative effect of all four sites (KB1, KB2, KB3 and KB4) would put a great strain on local services and facilities including roads as detailed above, health services and the Knebworth Primary School. The Knebworth Primary School is consistently oversubscribed year on year and with an intake of just 60 children per year, children living in Knebworth are often refused places. The addition of the proposed approximately 660 houses will greatly increase this demand and will be detrimental to both new residents moving into the new houses and current residents of Knebworth. The lack of a local secondary school results in high volumes of applicants to secondary schools in nearby towns Stevenage, Hitchin and Hertford from Knebworth. The proposed development will cause increased competition for secondary school places, which will again be to the detriment of both new residents moving into the new houses and current residents of Knebworth.

I have been reading the content of your Local Pan for North Herts and can only wonder where your qualified planners were at the time of it's preparation as they seem to have forgotten the very basics of planning.

As I see it, having been a member of the Chartered Management Institute, the process should go something like;
1. Establish where you are now
2. Establish a need, both now and for the foreseeable future
3. Consider the people involved
4. Put in place a viable plan of action that will take you from where you are now to where you need to be, taking into account;
a. Immediate capital projects needed to provide the infrastructure that will facilitate the main aim
b. Materials and funding to complete the project
c. Changes that may become apparent during the course of the project
d. Agreement from all parties involved in implementation

1. Congratulations! It seems you have completed point 1 successfully - up to a point. There are two main problems with the current situation that you have failed to mention;
a. The NHDC and Highways Departments are currently failing to provide adequate flood protection and drainage to the extent that some roads and junctions are dangerous to pedestrians and motorists whenever there is more than just a light rain. Complaints to the Parish Council, our Member of Parliament, Highways and NHDC have received nil response (copies of correspondence can be provided).
b. The lack on maintenance to the back roads of our village has resulted in erosion to embankments and subsequent deterioration the hard metal of the road surfaces at the edges, not to mention the general deterioration of road surfaces across the village, and indeed, across the county.
c. If this current lack of maintenance is due to lack of funding, how can you possibly expect to maintain an even larger housing stock with the subsequent increase in traffic movements?
Overall then, on point 1, it seems you have failed!

2. There were 2002 existing dwellings in Knebworth in 2011. Now you state the need to add a further 663 up to year 2030. That is a 33% increase - or nearly 10 times the 3% actual increase over the last 5 years (65 homes - completions and permissions). Bearing in mind we are only talking of a planning period up to 2030, unless there are factors you are not telling us about, we should only be looking at about 9% increase - 180 houses. Bearing in mind we will soon be exiting the European Union and the Government are committed to securing our borders which should slow down immigration, we may actually see a lesser need over the period. To justify your stated need for 663 new homes the local population would need to breed like rabbits! So on point 2, you have also failed.

3. Let us assume for a moment that most people are not fools. They will, without reservation accept that some development to provide sustainable growth will be required in their village. They will not, however, accept figures and plans thrust upon them without a logical explanation of how they were derived. The fact that some land owners see £ signs in front of their eyes when you ask if they are happy to give up their land for building is not justification for proposing to actually build on all those plots. So once again, on point 3, you have failed.

4. The people (residents) are bound to be concerned when they see proposals that are not backed up by sound planning. Apart from the proposal to provide relatively inadequate additional primary schooling and a possible secondary school (no details) your plans lack any infrastructure details to provide the necessary roads, drainage (both surface and foul - There is a major capacity issue at Rye Meads Sewage treatment Works), local employment opportunity or additional retail facilities. Indeed, you plan to reduce the retail facilities by putting housing on the Chas Lowe site.
At a previous Parish Council meeting The NHDC representative said that no infrastructure details had been included with your Local Plan as "it would be up to the individual house builders to submit proposals for roads, flood mitigation and drainage in their individual planning applications". This is a total abrogation of the Council's responsibility and the villagers will not stand for such a slap-dash attitude towards such a major proposed development. Again, NHDC, your Local Plan has failed.

Now let us consider some of the details, particularly on the west side of Knebworth, that proves your Local Plan is ill-conceived;

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

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

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

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

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

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

The bridge at Bridge Rod, Woolmer Green is the only bridge offering reasonable access to the west of Knebworth. So;
1. Put a roundabout at the junction B197/Bridge Road
2. Improve the road Wych Elm Lane by widening and straightening slightly up to Gypsy Lane
3. From where Gypsy Lane veers away from being next to, and parallel to, the A1(M) motorway, make a new road continuing parallel to the motorway, through your proposed Gypsy Lane development site, to meet and cross over Park Lane at a mini roundabout.
4. Continue the new road parallel to the motorway, through your proposed development site to the west of Deards End Lane Conservation Area, continuing along the very west fringe of Knebworth Golf Course (which would not interfere with their fairways), to cross over Old Knebworth Lane at a mini roundabout.
5. Continue the new road parallel to the motorway, through the west side of the proposed Science Park to meet the A602.

This proposal would address a whole host of problems;
* Pinch point at Knebworth High Street
* Access to the west side of Knebworth
* Relief road in the event of A1(M) closure between Stevenage south and Welwyn
* Congestion at peak times for traffic accessing the B197 from the A602
* Now that QEII Hospital A&E has been closed, emergency ambulances would have a shorter time to reach Lister Hospital in the event of traffic congestion
* Traffic from Welwyn west, Whitwell and Codicote and all points west would have easier access to Stevenage and beyond
Failure to adopt this proposal would be a major reason for your proposed development west of Knebworth to fail. Proposals 1 - 4 above would be the minimum to justify ANY development west of Knebworth.

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

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

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

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

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

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

Please see below my concerns with respect to your Local Plan 2011 - 2031 Proposed Submission Draft and in particular with regards to the village of Knebworth.

Re Section 2, 13, Communities, Knebworth:
Inadequate consideration has been applied with respect to selection of land for development in Knebworth in that:
1) It is predominantly land which is currently green belt and the use of green belt should only be considered in exceptional circumstances (as per your document). I have not seen any exceptional circumstances mentioned so struggle to understand why you are even thinking of requesting repurposing these plots of land.
2) Sites KB1 and KB2 are next to the A1M and with respect to this will have the problem of a) high noise and pollution levels next to residential properties b) no consideration of the pending widening of the A1M which is still on the plans for taking place c) extreme difficulty with large heavy construction vehicles attempting to access these sites and d) a school being developed next to the A1M on site KB2 which will cause safety concerns. Furthermore land which is currently under agricultural use which will be lost.
3) Site KB4 appears to be a very late addition to the plans and has accessibility issues for construction purposes and also will add a significant amount of traffic to roads which are narrow and already very busy. With Woolmer Green applying for turning green belt land (which is on the same side of the road as site KB4) into residential use then one sees the threat of land between the two sites being proposed for yet further development and with this the total loss of any separation with green land.
4) Site KB3 (centre of the village) appears to be predominantly for residential use. This means additional traffic and also pressure on local services (doctors, dentist...) and nothing in the plans that support bringing additional business development into Knebworth to help provide the opportunity of local employment to the increased population of people seeking employment.
5) The number of dwellings proposed has been increased from initial proposals and additionally no allowance/consideration has been taken into account with respect to land adjacent to the Odyssey Sports Club on which some 60+ residential properties have had planning approval? There is no justification for not including this development within the numbers for Knebworth.
6) Furthermore the repurposing of Green Belt land is contrary to Government policy and the proposed plans make no attempt to protect space between towns and villages in the area and this is significant to Knebworth in regard to Stevenage and Woolmer Green. Such plans, if approved, will erode the separate identity that Knebworth, as a village, has.

The addition of an excess of some 600+ residential properties in Knebworth has not really recognised the negative impact and issues which will arise:
1) The B197 was never built to accommodate such an increase in population and the village already suffers from significant traffic congestion and there is a shortfall in the centre of the village for parking for shoppers etc.
2) Areas of the village are difficult to access for large vehicles and there would be the necessity for such vehicles to attempt to gain access to planned sites and via one of the two railway bridges that exist and which are already danger points.
3) Lack of consideration for the local economy and nothing is proposed in respect to job creation or allocation of sites for commercial use. In fact the proposals show such land being removed with the planned development of site KB3.
4) Local NHS facilities will become more overstretched than they currently are - there is not even one full time NHS Dental provider in the village? Recognition needs to be given to the fact that Knebworth is a village and as such residents do need easy access to such NHS facilities - travelling to Stevenage , Welwyn Garden City or elsewhere is not going to be practical especially with Knebworth having an ageing population.
5) Building an additional, single form entry, junior school is neither cost effective from an operational perspective nor cost effective from a cost of build perspective. We currently have a very good two form entry Junior School in the village and this does operate cost effectively at present but with NHDC funding challenges it may well struggle in the not too distant future and especially with a second Junior School for NHDC to fund. I also understand that there are no monies available to fund the purchase of the land nor construction and setup of a new school and with this being the case one can only summise that the company that develop the facility on site KB2 will need to uplift the costs of each property that they develop and sell to cover such costs - something that I am sure they will not appreciate and especially with the cost of properties in Knebworth which are already at the higher end of the market. Unless there is a thoroughly considered and funded approach for this then it does not and will not stack up financially.
6) Additional traffic will occur, onto already highly used roads, by parents whose children attend school at the new site proposed in KB2. Such additional traffic will just add to the current overload and there are no alternative easy access points that would obviate such a position.
7) There does not appear to have been any consideration of the land that has already been secured and planning approved on the west of Stevenage. This site would provide for much more accommodation than Knebworth and other similar areas could provide and would also be able to provision commercial properties that would support and need additional employment which would be locally available.

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