Local Plan 2011-2031 Proposed Submission Draft

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.

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.

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.

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.

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.