Local Plan 2011-2031 Proposed Submission Draft
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Local Plan 2011-2031 Proposed Submission Draft
KB4 Land east of Knebworth
Representation ID: 1453
Received: 29/11/2016
Respondent: Mr Darren Bedford
Legally compliant? No
Sound? No
Duty to co-operate? No
I object to the Draft Local Plan for KB4.
The legality regarding KB4 only being proposed now and not on the previous consultation.
Green Belt - danger of coalescence, using land that is good for agricultural
Landscape - huge impact on the open landscape
Impact of traffic on local roads
Drainage issues
During the public consultancy between December 2014 and January, KB4 was not included in this document. So this is the only time its is going through this process. KB4 is the largest single site and has the most impact, especially being very close to Stevenage.
I have attached a letter from Stephen McPartland our local MP, backing up this point and brought into question the legality as it contrary to NHDC's declared process which is set out in the Town and Country Planning (Local Planning) Regulations 2012.
Knebworth is the largest village in Hertfordshire, it has 4496 residents in ca 2002 dwellings. The Local Plan is proposing a further 663 houses across four sites. Any other development of more than 500 houses in a single site, would have to have a Strategic Policy drawn up. Whilst none of the individual sites around the outskirts of Knebworth exceeds this number, the aggregate amount of proposed residences is 663, which represents over 31% increase to our village.
Knebworth has to be considered as one whole site rather than individual one. As the sites combined will have a significant impact on the infrastructure, transportation and highway. The B197 is the main access route and passes North-South through Knebworth High Street, which is already severely congested . All the sites would feed into the B197 and without any Strategic Policy for Knebworth is clear evidence that the Plan has not been positively prepared.
The plan is not Justified - One of the main reasons for Green Belt is prevent "coalescence." If the proposed local plan is allowed, in particular KB4 there would be almost continuous housing between Knebworth and Stevenage. Green belt is in place to maintain identity of the village for Knebworth and to stop urban sprawl.
The North of Knebworth is Stevenage , under the Stevenage Borough Council who, in their June 2015 Local Plan housing consultation, concluded that the land showing in the NHDC Plan as KB1 and KB4 make: - 'a significant contribution to Green Belt purposes.'
The proposed development of KB4 would breach three of the criteria defined in paragraph 80 of the National Planning Policy Framework, namely:
* to check the unrestricted sprawl of large built-up areas;
* to prevent neighbouring towns merging into one another; and
* To assist in safeguarding the countryside from encroachment.
The Local Plan correctly refers to Knebworth as a Category A village, whereas the supporting documentation refers to it as a 'town', which it is not.
The development on Green belt land would run contrary to:
o National Planning Policy; and
o the value the Council has placed on this land in its own Green Belt review, undertaken less than six months ago (July 2016).
It has also been highlighted that other areas of the existing Green belt, which are shown as simply making 'a moderate contribution to Green Belt purposes' are NOT being considered for residential development.
One of the test of "soundness" is that the Local Plan should be 'based on effective joint working on cross-border strategic priorities'. There seems to be a large discrepancy between the two authorities on whether this land is appropriate for building.
Previously Developed Land
KB4 is working agricultural land and has never been previously developed. It should, therefore, not be a priority for development.
Value of the land
The land in KB4 is classified as Grade 3, this being 'good to moderate'. It is therefore should be kept as such. It is not the poorest quality of land and, is in constant agricultural use. Removing good agricultural land , would have a permanent effect of the farming community and the a negative environmental impact.
To summarise:-
* 'a significant contribution to Green Belt purposes.'
* Currently preventing "coalescence"
* Is classed as "good to moderate" in agricultural terms
Visual Impact
Living in the village, you are surrounded by country side . The land is rising so therefore if the development goes ahead, it would completely change the characteristics of the village. The outlook and views would be dominated with houses.
Alternative Sites
The issues relating to the land to the West of Stevenage (section 4.104 of the Local Plan refers) should be resolved as soon as possible. This land can provide 3100 house and you will be able to ensure that there are services for all to benefit from. Rather than expanding villages that can't cope with the add houses.
The Plan is not Effective
Infrastructure
Transport:
In the consultation in 2014 it was discussed that 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 two railway bridges at either end of the village are not only extremely dangerous due the fact they are narrow for both vehicles and pedestrians but there is no way to improve them. If the proposal goes ahead the increase in volume of traffic and pedestrians will make this scarily dangerous. The narrow pathways under the bridges are frequently used by children, going to school. An increase of 31% of this scale can only escalate the issues. This matter has not been addressed at all and surely makes the plan not effective.
London Road, through the village- (B197) is also a known pinch point; it current takes over half an hour to reach junction 6 of the A1 in rush hour, which is only 2 miles away. (Increased traffic will only exacerbate this). Any issues on the A1M, Knebworth is a prime cut through. so therefore if the proposed housing were to be put in place and if there any closures on the A1M it could result in possibility of gridlock. No real back up for emergency vehicles. Which was actually the case a year ago.
Oakfields Road currently has not through exit. The road bends round into Oakfields avenue. Any access point to the proposed housing at KB4 would completely effect pedestrian right of way to the recreation park or the bridal path. Oakfields Road, which is off B197 is not wide enough to cope with the traffic that would result from the new development. The road also attracts commuter parking, which over the last months, has started encroach parts of the road during the working week.
During peak times, a number of roads are used to avoid the traffic, in particular: Old Lane, St Martin's Road, Swangleys Lane, Pondcroft and Gun Lane. These are very narrow and built up, it is already very dangerous for pedestrians, and the increase of 31% would only make it worse.
Swangleys Lane is another alternative route to access the B 197. It is a very narrow country lane with no pedistrian footpath after the Primary School. The road can become very restricted and often difficult for large farm vehicles to get past, especially during school drop off and pick up times (9, 12, 1515, 1630). At the end of the road, adjoining the B197 there is a pedestrian crossing and there is already congestion at this junction.
Watton Road is a narrow, winding, country lane, there is no space for safe passing for pedestrians or cyclists. During severe weather conditions, it has been extremely dangerous and has been closed on numerous occasions. Watton Road would be one possible access route to the B 197 from KB4.
Public Transport
Knebworth is a commuter village the Train station is extremely busy, it is already overcrowded and peak services have seen a 70% increase over the last ten years.
There is very little employment in the village and any new development would attract the commuter. Yet Govia Thameslink are under consultation to reduce the frequency of trains to/from the local station. Regardless of that, due to where the Station is based, the station is very popular and accessible to residents of Stevenage, this then increases the cars on the road and parking on local roads. The proposed housings would only increase this further and you will need to have permit parking as there is in inadequate commuter parking.
Parking
It has been mentioned the removal of parking on one side of the road through the village (London Road). This would only have a negative effect on village life - Loss of business for the local shops, which is already suffering. The parking on either side actually helps reduce the speed, therefore it would become unsafe with vehicles going even at the maximum speed. - a vehicle travelling at 30 mph can serious injure someone. Knebworth has a lovely community feel and restricting the parking in the centre of it, would just have a negative effect on village life.
During the day, the cars on either side, prevent traffic and Lorries speeding unnecessary through the village. The parking helps our local shops attract customers from a far, if you were to take parking away from one side, it will be the death of Knebworth villages high street, which is needed for all and in particular by many elderly residents.
Health Services
The doctor's surgery in Knebworth is currently located on Station road. They are in the process of looking for new premises. They have applied for planning permission but it would only improve the current service, which currently takes over 3 weeks to get an appointment. Even if this were successful, the new premises would not be adequate to cope with a 31% increase in the population of the village.
Dentist - there are two surgeries, only one which takes NHS patients, but that one has no capacity for new patients.
Drainage issues:
Drainage issues have been raised on a number of occasions. 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 only get worse with increased population and households.
Development in a neighbouring village of Woolmer Green for 150 houses , which lies on the B197 to the South of Knebworth, will only increase the levels of traffic flowing through Knebworth High Street and routes to A1M.
Is the Plan Consistent with National Policy?
I have attached a letter from Stephen McPartland. He states that there are significant failings in the way the Local Plan has been prepared. It very much has the feeling of a rush job and a numbers games, rather than a proper housing plan.
Duty to Co-Operate
The sites on Odyssey, north of Knebworth, has been granted planning permission for approx. 70-100 homes. This number of houses should surely be taken out of Knebworth's allocation and not just taken as a windfall.
As mentioned previously, Stevenage - West, has already been reserved for 3,100 homes. This would be a far better position to provide facilities and services, as the current plan for Knebworth has no support for current and new residents. As I understand that this is on hold is due to secondary school allocation. If a secondary school was built on that site, this would surely resolve this matter and stop adding on housing to over stretch villages.