Policy SP8: Housing

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Summary of why the proposed plan fails on grounds of "soundness"
- KB4 site inclusion has had no community involvement; and the legal compliance of doing so is questionable
- Coalescence. The removal of green belt land will create an urban sprawl into Stevenage
- Green belt land. Removing green belt land runs counter to national policy and the land of KB4 is identified in NHDC's own studies as being a "significant contribution" to the green belt; this contrasts with lesser green belt land which is not under proposal for development
- Infrastructure. The plan in its current form is uninformed and does not address significant local worries and realities with regards to how Knebworth would cope with a housing increase of 33%.
- Schooling (vague suggestions in the plan which are not mathematically sound)
- Doctors (currently at over capacity and the plan incorrectly says there will be a new doctors surgery; it will be a replacement surgery of the same size)
- Roads (KB4 will spans Watton Road, a road that is essentially a single track road due to on street parking; in addition parking in the village centre already creates significant congestion - "traffic modelling" suggested in the local plan appears to be desktop in nature and does not represent reality
- Trains (peak commuter trains are under threat from a down grade in frequency and timing from the current operator. They are at full capacity already. A population increase of +33% with no provision for employment opportunities in Knebworth or surrounding towns will lead to the obvious result of increased commuters into London)
- Bridges (the rail bridges can not be changed - with a particular dangerous pinch point vulnerable to increased traffic)
- Alternative options. The plan is not positively prepared as it ignores the option of a new garden city, or a more eloquent solution of using land sufficient for 3,000 homes to the west of Stevenage; bizarrely this land has been removed from the green belt for development but is not under consideration for development in this consultation
 
Is the plan "positively prepared"? No, for the following reasons the plan is NOT "sound"
1. No community involvement. Site KB4 has not previously been included as one of the sites which is a preferred option until this final plan. This is contrary to the Council's Statement of Community Involvement and therefore the legality of this site being included at all is questionable and it fails to meet the Legal Compliance criteria.
2. Residents have not been adequately listened to. This is demonstrated by the inclusion of site KB4 post the previous consultation document dated Dec-14. In the Dec-14 document the housing proposal was for 433 homes which contrasts to the current proposal of 663 homes. Given the objections formally submitted previously based on evidence including infrastructure deficiencies, I cannot see how the plan has been positively prepared to the point that the current proposal is for +53% more dwellings that the last consultation in Dec-14
3. Coalescence - Contrary to evidence in "North Hertfordshire Green Belt Review - July 2016". On page 20 of this review, it states that Knebworth green belt is of the highest strategic importance; "makes a significant contribution to Green Belt purposes, helping to prevent sprawl, merger and encroachment". It goes on further (page 42-43) to highlight again the "significant contribution" the green belt plays at site KB4 (e.g. 8b in the "Green Belt Review"), performing a vital "separation function" between Stevenage and Knebworth. Additionally land in this document (8c) which is site KB4 is cited as being an "elevated position creat[ing] a sense of openness". The removal of this would permanently damage the landscaping of Knebworth to the east of the village and create a sprawl into Stevenage
4. The plan includes inconsistent information with regards to Knebworth. Knebworth is a village (both by feel for the residents and definition in the plan as a category A village). This is contrary to supporting documents to the plan, namely the "North Hertfordshire Green Belt Review - July 2016". In this document, Knebworth is incorrectly defined as a town (2.1.11, page 9)
5. Infrastructure - the plan is not positively prepared as it fails to promote sustainable development as there is no reference to the infrastructure challenges Knebworth currently faces which will only accentuate with an increase in village size by 33%. See points 12 and 13 relating to infrastructure below.
6. Alternative solutions (West Stevenage) - there approach of North Herts District Council is not justified in the manner which it has discounted certain options which are both more viable, have fewer implementation challenges and would not damage the character or green belt of rural villages such as Knebworth. In the proposal Strategic Policy 8, paragraph 4.104 (page 50), the plan identifies an area of land west of the A1(M) and Stevenage which is "identified as a suitable location for a substantial urban extension to the town". It goes on to say that this site is being removed from the Green Belt and is to be "safeguarded for future use". This area of land is sufficient for c.3,000 homes which would easily mitigate the imposition of extra housing on green belts of existing villages with in adequate infrastructure. Stevenage has much greater capacity to absorb more housing that Knebworth does
7. Alternative Solutions (New Garden City) - The North Hertfordshire New Settlement Study (Apr-16) concludes that a new Garden City will be required in Hertfordshire post 2031 but this has been left too late for consideration in this consultation. It is clear that the plan in its current form has not been positively prepared and should be withdrawn as it is not assessing the options that are both (a) the most viable; and (b) the least disruptive and manageable within the constraints of local communities. A new Garden City would be able to take account of the needs for highways, social and affordable housing, education, health and other transport infrastructure.
 
Is the plan "justified"? No, for the following reasons the plan is NOT "sound"
8. Green Belt - there are no "exceptional circumstances" in any of the evidence to justify the destruction of the Green Belt around Knebworth, particularly on site KB4 which is working agriculture land. By permitting this development, the very existence of the Green Belt through to Stevenage will be at risk. I see that this is setting a precedent for destroying the green belt and lacks any understanding of what a village like Knebworth stands for. It is a village with a clear and distinct rural boundary which is both green belt and working agricultural land. Opening this up to developers is only positive for the developers who will profit substantially and is to the detriment to all residents (new and existing) of the village. There is no infrastructure plan which is a disaster - see section below
9. Green Belt - land on site KB4 in North Hertfordshire's own "North Hertfordshire Green Belt Review - July 2016" categorises the KB4 site as making "a significant contribution to the Green Belt" (pages 115 & 211, site ref 55, 56, 58, 211). The development of KB4 would "break the boundary" with Stevenage. It is therefore not justified or effective in line with the principles of Green Belt in the UK. It should be noted that of all the sites proposed in Knebworth, KB4 is the only site classified as making a "significant" contribution to the Green Belt, in contrast to the other sites that are classified as "moderate". Notwithstanding this point, the development of any of the sites in Knebworth do not address the major infrastructure points raised below.
10. Fairness - the plan is proposing to increase the village size by 33%, a much higher rate than other areas in North Hertfordshire and also other areas that do not have infrastructure constraints like Knebworth does (healthcare and rail at capacity, road congestion, flood risk etc)
11. Economy & Town Centres - there is no provision for local employment in the plan for Knebworth, in fact there is the risk of reducing employment opportunities due to the removal of site KB3 into residential properties and the mitigations that will likely be required to limit parking in the village centre which will have a knock on effect onto the strength of the remaining retail businesses. It is clear that the majority of the population growth proposed (+33%) in Knebworth will work outside of Knebworth, placing greater pressure on roads and the station which is already at capacity for peak commuter services into London.
 
Is the plan "effective"? No, for the following reasons the plan is NOT "sound"
12. The plan lacks any coherent strategic approach between housing, cumulative development and infrastructure need to support growth and sustainability. Rather it appears to be a box ticking exercise so North Herts Council can claim to have met the requirements of National Housing Policy by having a "plan". Whilst other developments in North Herts which have over 500 proposed new homes have the benefit of a Strategic Policy, this approach has not been adopted for Knebworth, despite 663 homes (a minimum) being forced on a community that already suffers from sub-standard and stretched infrastructure (see infrastructure below). This appears to be due purely to these homes being spread over "4" sites when in reality they are on 2 sites on east and west Knebworth which means that our community do not have a coherent Strategic Policy. Given the proposal in its current form has the number of dwellings increasing by 33% it would have been appropriate for Knebworth to have its own specific Strategic Policy which would have been able to address the challenges population growth in Knebworth will suffer from and therefore conclude in short order what the constraints are. Without this, there is the risk that piecemeal development leads to none of the infrastructure concerns being managed in a collective manner. Any Strategic Policy should cover:
a. Road access to the sites and the traffic implications
b. Educations
c. Parking implications (high street, Watton Road and Station parking)
13. The plan fails to address any of the crucial issues around adequacy of infrastructure which at present is very vulnerable and over stretched and would not be able to cope with an increase in the size of the village by 33%.
a. Roads - Roads and parking continue to be a major problem in Knebworth.
i. Knebworth is a "rat-run" used when the A1(M) is congested, for access to Welwyn Garden City and for access to South / East Stevenage / Hertford all of which takes traffic down Watton Road
ii. Watton Road (which will dissect KB4) - point 1. Watton Road is essentially a single track road from the mini roundabout through to the last house on Watton Road (number 49). It has speed bumps every 50-100 yards which funnel traffic into a single lane. In addition, cars are permanently parked on the north side of the road which makes it a single tracked road. The cars parked are a mixture of residents (who have more than 1 or 2 cars) and overflow onto the road, commuters using Knebworth train station and overflow from the recreational ground which houses a tennis club, bowls club, 2x play areas and 4 football pitches). As a consequence, the road is at all times log jammed meaning cars have to give way and drive on the pavement to pass each other creating a danger for young mothers and their children and elderly residents. I would welcome the Inspector to visit this road between the hours of 7-9am and 5-7pm to witness the volume of traffic and tailbacks this creates. I walk to the station in the morning and it is not uncommon for me to be walking much faster than the cars given the traffic.
iii. Watton Road (which will dissect KB4) - point 2. At the point where Watton Road becomes a country lane (past the entrance to Bell Close), it lacks central road markings demonstrating its unsuitability to carry more traffic and at speed. It has no provision for pedestrians or cyclists. It is already a dangerous stretch of road, hence the speed bumps were added in the approach into the village to limit speeds. It is also the access route for the crematorium meaning traffic volumes are high. KB4 is a highly unsuitable site to have incremental traffic and there is no evidence or planning proposed to address any of these issues meaning the plan as currently proposed is ineffective from the beginning.
iv. Other potential access points to KB4. As highlighted Watton Road is inadequate to service incremental traffic volume into KB4. Additionally, other roads into KB4 suffer from congestion and are inadequate. Swangleys Lane is not wide enough to cope with traffic from any new development. Haygarth is not viable to access B197 (London Road). Old Lane is too narrow and has already had measures to reduce its use enforced by changing the junction on to Watton Road to be one way. St Martins Road is a private road (no pavements) and traffic is accentuated in this area due to the School meaning tail backs are quite common. The replacement doctors surgery and redeveloped library on St Martin's road will only increase traffic in this area meaning any development of KB4 is not viable or effective based on accessibility.
v. "Transport Modelling" - the plan mentions very vaguely that there has been "transport modelling" and rather alarmingly states that said "modelling does not identify any specific mitigation scheme requirements for Knebworth". I, and the rest of our village, find such as statement to be highly irresponsible. There are severe issues with the robustness of Knebworth's road infrastructure which should the village increase in size by 33% as proposed would become insufferable and increase the risk of accidents (or death) on the roads.
vi. High Street - The plan does highlight the high street as a "pinch point" and vaguely says that this could be resolved through managing "short stay parking". This is inconsistent with other elements of the Strategic Plan which want to encourage employment and community in Knebworth. Without parking for the local businesses, they would have insufficient custom and would fail. This is quite a circular argument in the plan! Parking on the high street is only used for short stay parking and is essential to service local businesses.
vii. Railway underpass (Station Road) - This is one of the most dangerous pinch points in Knebworth where it is a single track road with only one very narrow pavement meaning pedestrians walking in opposite directions have to cross each other by stepping onto the road. The road width is only 4.5m, insufficient for two large vehicles so essentially it becomes a single lane. Road visibility on the approach to the tunnel is restricted due to the road alignment. For mothers with children and elderly residents it is already very dangerous. Having only one pavement through the tunnel requires multiple road crossings and associated danger with cars (often at high speeds) going to and from the station and village centre. The proposed sites at KB1, KB2, KB3 and KB4 would naturally divert traffic to this pinch point (as well as the High Street) creating greater volume of traffic, congestion and as consequence risk of accidents or death on the roads. The facts are that there is no mitigation for this, rather it is not effective for a village of Knebworth's size and historical infrastructure to house an extra 663 houses, an increase of 33%.
viii. Adjacent villages - the adjacent proposed developments in Codicote and Woolmer Green will also place additional pressure on Knebworth's roads and rail as it is used as a commuter station for other villages.
b. Rail (bridges)
i. The pinch point highlighted above cannot be mitigated given the cost and complexity of widening the bridges used to support the East Coast Mainline. The reality is that these will never be widened due to the complexity and the associated impact on train journeys (national and commuter) into London Kings Cross using this infrastructure. It is yet another reason why the plan is ineffective.
c. Rail (station capacity)
i. The station is already at full capacity for morning journeys into London. The fast journeys to London (0711 and 0811) are already standing room only with the platform full at these times with commuters. Current proposals by the train operator are to potentially reduce service numbers and remove these fast trains. The pressure on remaining services will therefore only increase, notwithstanding the impact of an extra 663 homes (+33% village size). The adjacent developments in Codicote and Woolmer Green will also place additional pressure on Knebworth's roads and rail as it is used as a commuter station for other villages. The plan is not effective in addressing this as there is no coherent linkage to rail infrastructure.
d. Doctors - the plan (paragraph 13.200) includes a misleading statement about a "new" doctors surgery. It fails to mention that this is a replacement doctors surgery to replace the current site on Station Road. This is highly misleading as the doctors surgery is already under immense pressure with GP appointment waiting times regularly 3-4 weeks away and often residents are directed to go to the Marymead Surgery in Stevenage as an alternative - an option which is not possible for those that are elderly or do not have a car. The site proposed for the replacement doctors surgery is already being challenged by local residents and there is clearly not enough room to develop this site any further to manage a population increase of 33% as currently proposed.
e. Schooling - Knebworth has one primary school and no secondary school, Secondary education provision is currently available in neighbouring towns such as Stevenage and Hitchin. The plan in its current form has a very limited and high level mitigation to the addition of 663 homes by suggesting a new primary school on KB1 and the even higher level notion of a possible "all through school" on KB4. Simple maths and assumptions based on 663 homes show that the lack of schooling would be a major issue. If one was to assume that there were 0.5 children per home from the ages of 4-11, additional children from the ages of 4-11 would be 331, based on classes of seven age groups at a primary school this would be 47 children per class. The statutory maximum number of children per class is 30 pupils; this highlights the huge black hole in this proposal on the inadequacy of schooling making the plan ineffective. This is not to mention the impact on the roads of additional "school runs" - see section above.
f. High Street Retail - Site KB3 is removing retail from the centre of Knebworth, which surely runs against trying to make Knebworth village centre a thriving centre.
g. Drainage - the plan has very vague statements that the Rye Meads wastewater draining facility near Hoddesdon "should" have sufficient capacity to handle all planned development within its catchment until at least 2026 and this downgraded to "reasonable prospect" for development through to 2031. This is clearly not an effective proposal for such as serious issue as water management and associated drainage. KB4 has specific issues with surface water drainage and often Watton Road looks like it is close to flooding.
 
Is the plan "consistent with national policy"? No, for the following reasons the plan is NOT "sound"
14. Consultation timeframe - this is the first time that KB4 has been included in any Local Plan as a preferred site for development. Including it now in this fashion with limited time for consideration and comment is out of line with standard national planning cycles and processes. As a result, NHDC could be sanctioned for not following agreed due process.
15. Green Belt - The development of land on KB4 would breach criteria set out in the National Planning Policy Framework (paragraph 80) in relation to the purpose of green belt land. These conditions include:
a. To prevent neighbouring towns merging into one another;
b. To assist in safeguarding the countryside from encroachment; and
c. To check the unrestricted sprawl of large built up areas
16. Coalescence - this is one of the main reasons for the existence of green belt land, in order to prevent neighbouring conurbations to merge and become an urban sprawl. The current local plan runs counter to this and essentially is sanctioning a north to south sprawl from Stevenage, through Knebworth into Welwyn Garden City and through to Hatfield. Green Belt land on site KB4 in North Hertfordshire's own "North Hertfordshire Green Belt Review - July 2016" categorises the KB4 site as making "a significant contribution to the Green Belt" (pages 115 & 211, site ref 55, 56, 58, 211). The development of KB4 would "break the boundary" with Stevenage. It is therefore not justified or effective in line with the principles of Green Belt in the UK. It should be noted that there are other sites noted as a "moderate contribution to green belt" which have not been proposed for development.
17. Agriculture Land - KB4 is working agricultural land and is classified as "good to moderate" in the supporting documents. Development would impact the operation of Swangleys Farm which is a working farm with Swangleys Road the only road accessible to move heavy agriculture machinery and for heavy transportation to move crops to market. The removal of working good quality land is counter to national agriculture policy.
18. Landscape - Site KB4 in particular will destroy the landscape to the east of Knebworth and create an urban sprawl merging with Stevenage. If allowed to be developed it will dominate the sky line given the undulations in the land around Knebworth

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).

Summary of why the proposed plan fails on grounds of soundness
- KB4 site inclusion has had no community involvement; and the legal compliance of doing so is questionable
- Coalescence. The removal of green belt land will create an urban sprawl into Stevenage
- Green belt land. Removing green belt land runs counter to national policy and the land of KB4 is identified in NHDC's own studies as being a significant contribution; to the green belt; this contrasts with lesser green belt land which is not under proposal for development
- Infrastructure. The plan in its current form is uninformed and does not address significant local worries and realities with regards to how Knebworth would cope with a housing increase of 33%.
- Schooling (vague suggestions in the plan which are not mathematically sound)
- Doctors (currently at over capacity and the plan incorrectly says there will be a new doctors surgery; it will be a replacement surgery of the same size)
- Roads (KB4 will spans Watton Road, a road that is essentially a single track road due to on street parking; in addition parking in the village centre already creates significant congestion - traffic modelling; suggested in the local plan appears to be desktop in nature and does not represent reality
- Trains (peak commuter trains are under threat from a down grade in frequency and timing from the current operator. They are at full capacity already. A population increase of +33% with no provision for employment opportunities in Knebworth or surrounding towns will lead to the obvious result of increased commuters into London)
- Bridges (the rail bridges can not be changed - with a particular dangerous pinch point vulnerable to increased traffic)
- Alternative options. The plan is not positively prepared as it ignores the option of a new garden city, or a more eloquent solution of using land sufficient for 3,000 homes to the west of Stevenage; bizarrely this land has been removed from the green belt for development but is not under consideration for development in this consultation
 
Is the plan positively prepared? No, for the following reasons the plan is NOT und
1. No community involvement. Site KB4 has not previously been included as one of the sites which is a preferred option until this final plan. This is contrary to the Council's Statement of Community Involvement and therefore the legality of this site being included at all is questionable and it fails to meet the Legal Compliance criteria.
2. Residents have not been adequately listened to. This is demonstrated by the inclusion of site KB4 post the previous consultation document dated Dec-14. In the Dec-14 document the housing proposal was for 433 homes which contrasts to the current proposal of 663 homes. Given the objections formally submitted previously based on evidence including infrastructure deficiencies, I cannot see how the plan has been positively prepared to the point that the current proposal is for +53% more dwellings that the last consultation in Dec-14
3. Coalescence - Contrary to evidence in North Hertfordshire Green Belt Review - July 2016. On page 20 of this review, it states that Knebworth green belt is of the highest strategic importance; makes a significant contribution to Green Belt purposes, helping to prevent sprawl, merger and encroachment. It goes on further (page 42-43) to highlight again the significant contribution the green belt plays at site KB4 (e.g. 8b in the "Green Belt Review"), performing a vital separation function between Stevenage and Knebworth. Additionally land in this document (8c) which is site KB4 is cited as being an elevated position creat[ing] a sense of openness. The removal of this would permanently damage the landscaping of Knebworth to the east of the village and create a sprawl into Stevenage
4. The plan includes inconsistent information with regards to Knebworth. Knebworth is a village (both by feel for the residents and definition in the plan as a category A village). This is contrary to supporting documents to the plan, namely the North Hertfordshire Green Belt Review - July 2016. In this document, Knebworth is incorrectly defined as a town (2.1.11, page 9)
5. Infrastructure - the plan is not positively prepared as it fails to promote sustainable development as there is no reference to the infrastructure challenges Knebworth currently faces which will only accentuate with an increase in village size by 33%. See points 12 and 13 relating to infrastructure below.
6. Alternative solutions (West Stevenage) - there approach of North Herts District Council is not justified in the manner which it has discounted certain options which are both more viable, have fewer implementation challenges and would not damage the character or green belt of rural villages such as Knebworth. In the proposal Strategic Policy 8, paragraph 4.104 (page 50), the plan identifies an area of land west of the A1(M) and Stevenage which is "identified as a suitable location for a substantial urban extension to the town". It goes on to say that this site is being removed from the Green Belt and is to be safeguarded for future use. This area of land is sufficient for c.3,000 homes which would easily mitigate the imposition of extra housing on green belts of existing villages with in adequate infrastructure. Stevenage has much greater capacity to absorb more housing that Knebworth does
7. Alternative Solutions (New Garden City) - The North Hertfordshire New Settlement Study (Apr-16) concludes that a new Garden City will be required in Hertfordshire post 2031 but this has been left too late for consideration in this consultation. It is clear that the plan in its current form has not been positively prepared and should be withdrawn as it is not assessing the options that are both (a) the most viable; and (b) the least disruptive and manageable within the constraints of local communities. A new Garden City would be able to take account of the needs for highways, social and affordable housing, education, health and other transport infrastructure.
 
Is the plan justified? No, for the following reasons the plan is NOT sound
8. Green Belt - there are no exceptional circumstances in any of the evidence to justify the destruction of the Green Belt around Knebworth, particularly on site KB4 which is working agriculture land. By permitting this development, the very existence of the Green Belt through to Stevenage will be at risk. I see that this is setting a precedent for destroying the green belt and lacks any understanding of what a village like Knebworth stands for. It is a village with a clear and distinct rural boundary which is both green belt and working agricultural land. Opening this up to developers is only positive for the developers who will profit substantially and is to the detriment to all residents (new and existing) of the village. There is no infrastructure plan which is a disaster - see section below
9. Green Belt - land on site KB4 in North Hertfordshire's own North Hertfordshire Green Belt Review - July 2016 categorises the KB4 site as making a significant contribution to the Green Belt (pages 115 & 211, site ref 55, 56, 58, 211). The development of KB4 would break the boundary with Stevenage. It is therefore not justified or effective in line with the principles of Green Belt in the UK. It should be noted that of all the sites proposed in Knebworth, KB4 is the only site classified as making a significant contribution to the Green Belt, in contrast to the other sites that are classified as moderate. Notwithstanding this point, the development of any of the sites in Knebworth do not address the major infrastructure points raised below.
10. Fairness - the plan is proposing to increase the village size by 33%, a much higher rate than other areas in North Hertfordshire and also other areas that do not have infrastructure constraints like Knebworth does (healthcare and rail at capacity, road congestion, flood risk etc)
11. Economy and Town Centres - there is no provision for local employment in the plan for Knebworth, in fact there is the risk of reducing employment opportunities due to the removal of site KB3 into residential properties and the mitigations that will likely be required to limit parking in the village centre which will have a knock on effect onto the strength of the remaining retail businesses. It is clear that the majority of the population growth proposed (+33%) in Knebworth will work outside of Knebworth, placing greater pressure on roads and the station which is already at capacity for peak commuter services into London.
 
Is the plan effective? No, for the following reasons the plan is NOT sound
12. The plan lacks any coherent strategic approach between housing, cumulative development and infrastructure need to support growth and sustainability. Rather it appears to be a box ticking exercise so North Herts Council can claim to have met the requirements of National Housing Policy by having a plan. Whilst other developments in North Herts which have over 500 proposed new homes have the benefit of a Strategic Policy, this approach has not been adopted for Knebworth, despite 663 homes (a minimum) being forced on a community that already suffers from sub-standard and stretched infrastructure (see infrastructure below). This appears to be due purely to these homes being spread over 4 sites when in reality they are on 2 sites on east and west Knebworth which means that our community do not have a coherent Strategic Policy. Given the proposal in its current form has the number of dwellings increasing by 33% it would have been appropriate for Knebworth to have its own specific Strategic Policy which would have been able to address the challenges population growth in Knebworth will suffer from and therefore conclude in short order what the constraints are. Without this, there is the risk that piecemeal development leads to none of the infrastructure concerns being managed in a collective manner. Any Strategic Policy should cover:
a. Road access to the sites and the traffic implications
b. Educations
c. Parking implications (high street, Watton Road and Station parking)
13. The plan fails to address any of the crucial issues around adequacy of infrastructure which at present is very vulnerable and over stretched and would not be able to cope with an increase in the size of the village by 33%.
a. Roads - Roads and parking continue to be a major problem in Knebworth.
i. Knebworth is a rat-run used when the A1(M) is congested, for access to Welwyn Garden City and for access to South / East Stevenage / Hertford all of which takes traffic down Watton Road
ii. Watton Road (which will dissect KB4) - point 1. Watton Road is essentially a single track road from the mini roundabout through to the last house on Watton Road (number 49). It has speed bumps every 50-100 yards which funnel traffic into a single lane. In addition, cars are permanently parked on the north side of the road which makes it a single tracked road. The cars parked are a mixture of residents (who have more than 1 or 2 cars) and overflow onto the road, commuters using Knebworth train station and overflow from the recreational ground which houses a tennis club, bowls club, 2x play areas and 4 football pitches). As a consequence, the road is at all times log jammed meaning cars have to give way and drive on the pavement to pass each other creating a danger for young mothers and their children and elderly residents. I would welcome the Inspector to visit this road between the hours of 7-9am and 5-7pm to witness the volume of traffic and tailbacks this creates. I walk to the station in the morning and it is not uncommon for me to be walking much faster than the cars given the traffic.
iii. Watton Road (which will dissect KB4) - point 2. At the point where Watton Road becomes a country lane (past the entrance to Bell Close), it lacks central road markings demonstrating its unsuitability to carry more traffic and at speed. It has no provision for pedestrians or cyclists. It is already a dangerous stretch of road, hence the speed bumps were added in the approach into the village to limit speeds. It is also the access route for the crematorium meaning traffic volumes are high. KB4 is a highly unsuitable site to have incremental traffic and there is no evidence or planning proposed to address any of these issues meaning the plan as currently proposed is ineffective from the beginning.
iv. Other potential access points to KB4. As highlighted Watton Road is inadequate to service incremental traffic volume into KB4. Additionally, other roads into KB4 suffer from congestion and are inadequate. Swangleys Lane is not wide enough to cope with traffic from any new development. Haygarth is not viable to access B197 (London Road). Old Lane is too narrow and has already had measures to reduce its use enforced by changing the junction on to Watton Road to be one way. St Martins Road is a private road (no pavements) and traffic is accentuated in this area due to the School meaning tail backs are quite common. The replacement doctors surgery and redeveloped library on St Martin's road will only increase traffic in this area meaning any development of KB4 is not viable or effective based on accessibility.
v. Transport Modelling - the plan mentions very vaguely that there has been transport modelling and rather alarmingly states that said modelling does not identify any specific mitigation scheme requirements for Knebworth. I, and the rest of our village, find such as statement to be highly irresponsible. There are severe issues with the robustness of Knebworth's road infrastructure which should the village increase in size by 33% as proposed would become insufferable and increase the risk of accidents (or death) on the roads.
vi. High Street - The plan does highlight the high street as a pinch point and vaguely says that this could be resolved through managing short stay parking. This is inconsistent with other elements of the Strategic Plan which want to encourage employment and community in Knebworth. Without parking for the local businesses, they would have insufficient custom and would fail. This is quite a circular argument in the plan! Parking on the high street is only used for short stay parking and is essential to service local businesses.
vii. Railway underpass (Station Road) - This is one of the most dangerous pinch points in Knebworth where it is a single track road with only one very narrow pavement meaning pedestrians walking in opposite directions have to cross each other by stepping onto the road. The road width is only 4.5m, insufficient for two large vehicles so essentially it becomes a single lane. Road visibility on the approach to the tunnel is restricted due to the road alignment. For mothers with children and elderly residents it is already very dangerous. Having only one pavement through the tunnel requires multiple road crossings and associated danger with cars (often at high speeds) going to and from the station and village centre. The proposed sites at KB1, KB2, KB3 and KB4 would naturally divert traffic to this pinch point (as well as the High Street) creating greater volume of traffic, congestion and as consequence risk of accidents or death on the roads. The facts are that there is no mitigation for this, rather it is not effective for a village of Knebworth's size and historical infrastructure to house an extra 663 houses, an increase of 33%.
viii. Adjacent villages - the adjacent proposed developments in Codicote and Woolmer Green will also place additional pressure on Knebworth's roads and rail as it is used as a commuter station for other villages.
b. Rail (bridges)
i. The pinch point highlighted above cannot be mitigated given the cost and complexity of widening the bridges used to support the East Coast Mainline. The reality is that these will never be widened due to the complexity and the associated impact on train journeys (national and commuter) into London Kings Cross using this infrastructure. It is yet another reason why the plan is ineffective.
c. Rail (station capacity)
i. The station is already at full capacity for morning journeys into London. The fast journeys to London (0711 and 0811) are already standing room only with the platform full at these times with commuters. Current proposals by the train operator are to potentially reduce service numbers and remove these fast trains. The pressure on remaining services will therefore only increase, notwithstanding the impact of an extra 663 homes (+33% village size). The adjacent developments in Codicote and Woolmer Green will also place additional pressure on Knebworth's roads and rail as it is used as a commuter station for other villages. The plan is not effective in addressing this as there is no coherent linkage to rail infrastructure.
d. Doctors - the plan (paragraph 13.200) includes a misleading statement about a "new" doctors surgery. It fails to mention that this is a replacement doctors surgery to replace the current site on Station Road. This is highly misleading as the doctors surgery is already under immense pressure with GP appointment waiting times regularly 3-4 weeks away and often residents are directed to go to the Marymead Surgery in Stevenage as an alternative - an option which is not possible for those that are elderly or do not have a car. The site proposed for the replacement doctors surgery is already being challenged by local residents and there is clearly not enough room to develop this site any further to manage a population increase of 33% as currently proposed.
e. Schooling - Knebworth has one primary school and no secondary school, Secondary education provision is currently available in neighbouring towns such as Stevenage and Hitchin. The plan in its current form has a very limited and high level mitigation to the addition of 663 homes by suggesting a new primary school on KB1 and the even higher level notion of a possible "all through school" on KB4. Simple maths and assumptions based on 663 homes show that the lack of schooling would be a major issue. If one was to assume that there were 0.5 children per home from the ages of 4-11, additional children from the ages of 4-11 would be 331, based on classes of seven age groups at a primary school this would be 47 children per class. The statutory maximum number of children per class is 30 pupils; this highlights the huge black hole in this proposal on the inadequacy of schooling making the plan ineffective. This is not to mention the impact on the roads of additional school runs - see section above.
f. High Street Retail - Site KB3 is removing retail from the centre of Knebworth, which surely runs against trying to make Knebworth village centre a thriving centre.
g. Drainage - the plan has very vague statements that the Rye Meads wastewater draining facility near Hoddesdon "should" have sufficient capacity to handle all planned development within its catchment until at least 2026 and this downgraded to reasonable prospect for development through to 2031. This is clearly not an effective proposal for such as serious issue as water management and associated drainage. KB4 has specific issues with surface water drainage and often Watton Road looks like it is close to flooding.
 
Is the plan consistent with national policy? No, for the following reasons the plan is NOT sound
14. Consultation timeframe - this is the first time that KB4 has been included in any Local Plan as a preferred site for development. Including it now in this fashion with limited time for consideration and comment is out of line with standard national planning cycles and processes. As a result, NHDC could be sanctioned for not following agreed due process.
15. Green Belt - The development of land on KB4 would breach criteria set out in the National Planning Policy Framework (paragraph 80) in relation to the purpose of green belt land. These conditions include:
a. To prevent neighbouring towns merging into one another;
b. To assist in safeguarding the countryside from encroachment; and
c. To check the unrestricted sprawl of large built up areas
16. Coalescence - this is one of the main reasons for the existence of green belt land, in order to prevent neighbouring conurbations to merge and become an urban sprawl. The current local plan runs counter to this and essentially is sanctioning a north to south sprawl from Stevenage, through Knebworth into Welwyn Garden City and through to Hatfield. Green Belt land on site KB4 in North Hertfordshire's own North Hertfordshire Green Belt Review - July 2016 categorises the KB4 site as making a significant contribution to the Green Belt (pages 115 & 211, site ref 55, 56, 58, 211). The development of KB4 would break the boundary with Stevenage. It is therefore not justified or effective in line with the principles of Green Belt in the UK. It should be noted that there are other sites noted as a moderate contribution to green belt which have not been proposed for development.
17. Agriculture Land - KB4 is working agricultural land and is classified as good to moderate in the supporting documents. Development would impact the operation of Swangleys Farm which is a working farm with Swangleys Road the only road accessible to move heavy agriculture machinery and for heavy transportation to move crops to market. The removal of working good quality land is counter to national agriculture policy.
18. Landscape - Site KB4 in particular will destroy the landscape to the east of Knebworth and create an urban sprawl merging with Stevenage. If allowed to be developed it will dominate the sky line given the undulations in the land around Knebworth

I wish to object very strongly to the NHDC Local Plan 2011-2031 proposals relating to development at Great Ashby (referenced GA1 and GA2 - comprising 330 and 600 houses respectively ), especially GA1 (Roundwood). Both sites are within the Green Belt and my reasons are as follows:

* Due to its location at the extreme edge of the NHDC area, development at GA1 and GA2 does not address the housing needs of North Herts and therefore no 'exceptional circumstances' have been demonstrated which would warrant relaxing planning restrictions in the Green Belt (GB). Development here would be to serve the needs of Stevenage only. Stevenage planners should be looking to resolve their own housing needs (using brown field sites, more flats, better use of available land, etc), but if NHDC wish to work with Stevenage to solve their housing needs they should collaborate on more appropriate and most importantly, sustainable sites, such as West of Stevenage (with its close proximity to the town centre shopping district, business and leisure centres, rail/road connections) .This is the most logical and sustainable area for development in the Stevenage area and should be the first priority for development, rather than designating it as 'safeguarded land' for development at a later date.

* The current GB boundary at GA1 along Weston Road has already been re-located once as part of the wider GB expansion to enable the initial Great Ashby development to be built (which now comprises approximately 3,000 homes) and was only completed in 2011. When defining the boundary, planners would/should have satisfied themselves that the boundary would endure and not need to be altered, in accordance with guidance current at that time and with current NPPF policy. By developing at GA1 and GA2 NHDC would effectively be moving the GB boundary for as second time in this location. Other more appropriate sites should be considered before re-defining the Stevenage boundary here for a second time.

* Weston Road was selected by planners to define the GB boundary in the location of the proposed GA1 area, because it was considered 'robust' and 'defensible' and this was endorsed by the Environment Secretary of the time, Nicholas Ridley. I understand the condition of 'exceptional circumstances' already existed at that time, so if the current boundary was designed to be robust and defensible then, why is NHDC planning to disregard it and develop within the GB. This is completely against one of the key objectives of GB policy which is their permanence.

* Development at GA1 (and to a lesser extent GA2) is not sustainable and therefore should not be considered for housing. The proposed plan already acknowledges there would be significant problems with development here.

Developing the sites at GA1 and GA2 on the edge of Stevenage would have the effect of moving the green belt margin further away from Stevenage. According to the NPPF, when reviewing GB boundaries planners should 'take account of the need to promote sustainable patterns of development' (NPPF). Development at GA1 would not be sustainable and therefore extending Stevenage into the GB at these locations should not be considered. All the access roads to a potential development at GA1 are very narrow and widening would be either impossible or impractical. To be viable there would need to be a link road around the north of the sites, either connecting Great Ashby to A1M at Junction 8 or to more major roads into Stevenage. This would be either very expensive or in the latter case impossible due to the lack of available land/narrow roads through residential areas. There is no provision for such a road in the development plans.

The country lanes from Gravely and Weston are barely passable for 2 cars and Calder Way which would link GA1 to the rest of Great Ashby is traffic calmed, single track and with houses on both sides, so the development would not be easily accessible by car and impossible by bus. It is understood a new local access road linking Great Ashby to GA1 via Hay Bluff Drive (crossing Weston Road) is being considered by developers, but again Hay Bluff Drive is too narrow and frequently choked with parked cars, due to the failure of earlier planners/developers to insist on sufficient parking provision in the existing Great Ashby development. Parking is a particular problem as Great Ashby has one of the highest concentrations of homes of multiple occupancy (HMOs) in the county. Widening Hay Bluff Drive to accommodate buses for GA1 would just exacerbate an already intolerable parking problem, according to local residents. They are concerned that emergency services may not be able to access houses in the HBD/Martins Way area already, so taking away more parking spaces to widen access could make the area unsafe.

* Calder Way which would link GA1 to the rest of Great Ashby/Stevenage is single track. This narrow (and very effective) traffic calmed road was specifically included as a planning condition of the first phase of development at Great Ashby, to reduce rat running from Stevenage through Weston and Gravely. To make GA1 sustainable there would have to be better access to the site (as discussed above). This would specifically breach the traffic calming (effectively voiding the planning condition which has proved so effective to date) and would result in the flood gates being opened for rat running from all over Stevenage into Gravely and Weston. Breaching this earlier planning condition is totally unacceptable.

* One of the key purposes of GB is to assist in safeguarding the countryside from encroachment. Development at GA1 and GA2 will result in very significant encroachment into the countryside around the hamlets of Warrens Green and Halls Green, as well as the village of Weston.

Similarly, GB is designated to 'prevent urban sprawl' by keeping land permanently 'open'. Development at GA1 and GA2 will contribute yet again to the continued urban sprawl of Stevenage with the resultant slow merging of Stevenage, Hitchin , Letchworth and Baldock, all of which causes great harm to the GB and is completely contrary to GB guidance. Planning guidance states 'special circumstances' will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations' (NPPF). The proposed plan gives no explanation of why planners consider this harm is outweighed by other considerations in these locations. I do not believe it is.

* The proposed developments do not appear to have clear boundaries that would be defensible in future, (contrary to the NPPF) and further coalescence with Halls Green, Warrens Green and Weston would be inevitable, in the short term.

* It seems NHDC have based their proposal for development s GA1 and GA2 on the land being made available for development by the land owner and the desire of a developer to pursue a development, rather than any sound planning criteria.
I am not opposed to appropriate development in GB in accordance with planning guidance, where appropriate eg in my own village of Weston. Here the proposed development and effective new GB boundary is logical, defensible, durable and importantly development on the released land would be accessible, sustainable and clearly defined by the main road into the village.

I do not believe any criteria for demonstrating exceptional circumstances are met at GA2 or GA1. Neither site is sustainable and GA1 especially should be taken out of the Plan altogether. Efforts should be concentrated on West of Stevenage development and other proposed locations where exceptional circumstances can be demonstrated.

I am objecting to this proposal on the following grounds:

There are sufficient undeveloped Brown field sites to meet unmet housing need.

The removal of this land from the Green Belt leaves it unprotected from applications from developers.

The local infrastructure surrounding this area cannot cope with the significant increase in traffic flow, air and noise pollution and already over-stretched medical and emergency services arising from any such applications.

The proposal to re-designate this land will also have a devastating and irreversible effect on wildlife.

1) Luton's unmet need for housing is not an exceptional circumstance justifying removing Green Belt Status. From living in Luton previously, I know a lot of brownfield sites within Luton have not been developed.

2) This development will cause traffic chaos through local villages like Lilley and Offley where commuters will be looking for shortcuts to the M1/Hitchin/Stevenage. The impact has not been studied nor mitigated against.

3) 2,100 homes (14% of the total allocation) is totally out of proportion, swallowing whole hamlets (205 homes) and integrating them into Wigmore which is part of Luton

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Please see attachments:
Preston Parish Council, sites EL1, El2, EL3
Extract from NHDC meeting 20 July 2016
Letter from Brandon Lewis on green belt land

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1) Luton's unmet need for housing is not an exceptional circumstance justifying removing Green Belt Status. From living in Luton previously, I know a lot of brownfield sites within Luton have not been developed.

2) This development will cause traffic chaos through local villages like Lilley and Offley where commuters will be looking for shortcuts to the M1/Hitchin/Stevenage. The impact has not been studied nor mitigated against.

3) 2,100 homes (14% of the total allocation) is totally out of proportion, swallowing whole hamlets (205 homes) and integrating them into Wigmore which is part of Luton.

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2800 houses means over 5000 cars on an estate like this. These cars will want to travel west because their employment and shopping facilities predominantly exist that direction. This will produce traffic chaos to Baldock on a grand scale.

Baldock is a small Market Town with limited facilities in a compact town centre. Apart from the old Kayser Bondor building becoming a large supermarket, which is used by many car driving North Herts residents, there have been no other facility changes for decades.
There is no room in and around the centre to increase its size. The facilities are designed for a small sized town with very limited parking spaces. Any further major development will completely destroy the whole character of the town

This increase (80%) in size is not logical. The town is only just coping today so adding this number of houses can only lead to chaos. Too much traffic, not enough parking and even more pollution increasing the unacceptable level that it has currently reached.

The traffic flowing through the town has easily exceeded the levels experienced pre-1966 i.e. before the A1 bypass and the more recently built east bypass. These two road changes, though important for the town, have not stopped the volumes of through traffic and the poor health implications that go with it. Unless something is done about this traffic (the solution is quite simple, which I can explain if requested), any further development will lead to chaotic lifestyles for all residents.

The NHDC presenters of this plan have not given the above serious thought at all. I believe the one and only reason for the 2800 house site is AS STATED IN THE PROPOSALS, that the site will not be contested by the landowner, HCC, and therefore building can happen quickly on this site to achieve a statutory numbers' requirement. There has been very little consultation about testing alternative sites around Baldock that would make more sense. This has been a hurried submission due to the lack of input in prior years to resolve the National Housing dilemma.

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I am writing to you in relation to the proposed development in Whitwell - Site SP2. Please see below my reasoning. I look forward to this being considered in the appropriate way.

Object to Chapter 4, Policy SP8
1. The proposed plan to provide housing on this site will be a huge detriment of the open countryside.
2. SP2, has been added at a very late stage and should be removed as it is not needed.
3. There is no policy basis for increasing the buffer from the previously accepted 3% to 7%
Object to Chapter 4, Policy SP2
1. The plan is not sound as the evidence used to identify sustainable villages is flawed.
2. This results in isolated villages with no facilities such as a senior school and shops and very little public transport being seen as suitable for significant development.
3. In addition Whitwell is accessed by narrow lanes often requiring passing places and is already hugely congested and dangerous.
4. More evidence is needed on impact on car usage. Whitwell should be categorised as a 'B' village
Object to Chapter 13, Site Allocation SP2
1. There is no need for SP2 to meet housing need. The NHDC approach is not sound. It does not comply with NPPF as no consideration has been taken of flood risk and a sequential approach has not been followed in site selection.
2. SP2 was added at a late stage with an allocation of greater than 5ha - this conflicts with NHDC evidence that large housing extensions to Whitwell could have an unacceptable visual impact due to high visual sensitivities associated with cross country views
Object to Chapter 13, site allocation SP2
1. The site has a known and identified high risk of surface water flooding as recognised in the Council's Strategic Flood Risk Assessment. The NPPF states that development should be steered to areas with the lowest chance of flooding.
2. Site SP2 should only be considered if there is an identified need that cannot be met elsewhere with a lower probability of flooding
Object to Chapter 13, site allocation SP2
1. The proposed development is not in a sustainable location and will depend on private transport for most travel.
2. The NHDC Planning Committee on August 25 determined that required sustainable drainage (SUDS) would have unacceptable impact on the visual impact of the site and the application was refused. Alternative solutions will require underground tanks and pumps which are also not sustainable
NPPF Requirement to empower local people to shape their surroundings (Paragraph 150)
1. The Local Plan has ignored our local community. NHDC is well aware of the local feeling towards potential development on this site. The site is not needed to meet the identified housing need and yet NHDC Planners remain determined to use this site even with known objections, environmental and flooding concerns together with the visual impact on the intrinsic beauty of the countryside.
2. Thames Water state lack of sewerage capacity. The Planners even ignore their own Planning Committee who recently rejected the site for development
Object to the allocation of SP2 for housing
1. The Local Plan Preferred Option allocated the site for Green Belt. This was fully supported by the Parish Council. NHDC has provided no justification for the site no longer being categorised as Green Belt.
2. Latest figures (reduction in OAN) show that SP2 is not needed for housing. Green Belt status is also needed to mitigate for Green Belt losses elsewhere in the District where additional housing is being provided in more sustainable locations. The Local Plan pragmatically adds in late sites.
3. The submission has not given the Parish Council or villagers the opportunity to be empowered and ignored their wishes for SP2 to remain Green Belt
For the reasons above I/we consider that SP2 should be removed from the 2011 - 2031 Local Plan

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