Policy ETC8: Tourism

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Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 3904

Received: 29/11/2016

Respondent: Letchworth Garden City Heritage Foundation

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes


Support the aspirations of the policy but the policy could be widened to be more supportive of rural areas as well as town centres.

Tourism related activities could also be encouraged within a specific Tourism Strategy.

Full text:

See attached


Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4270

Received: 30/11/2016

Respondent: Knebworth Estates

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified


Object to ETC8: Support Plan's commitment to tourism but plan should be more positive on this, importance of Knebworth House in this regard, plan should be aspirational to the benefits and potential of tourism.

Full text:

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:


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.


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/).


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".


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.


Local Plan 2011-2031 Proposed Submission Draft

Representation ID: 4335

Received: 29/11/2016

Respondent: Fairview Hotels & Healthcare Ltd

Agent: Waller Planning

Legally compliant? Yes

Sound? No

Duty to co-operate? Yes


Object to ETC8: Fails to consider wider functions of hotels e.g. conferencing facilities, failure to identify need for conference facilities or economic benefits

Full text:

See attached