Local Plan 2011-2031 Proposed Submission Draft

The plan is not justified as the exceptional circumstances for removal of Green Belt around Knebworth (sites KB1,2,4). These sites provide a significant contribution to maintaining the spacial strategy between Stevenage, the villages and Welwyn Garden City along the B197. The identify of Knebworth is under threat from co-existence with Stevenage and Woolmer Green. NHDC does not appears to have co-operated with Welwyn Hatfield Borough Council on their submitted Local Plan as the impact of site HS15 (150 homes) on the boundary with Knebworth has not been considered in the assessments for Knebworth.

The plan is unsound for Knebworth village as a whole, it is cumulatively unsustainable and risks creating a congested B197 housing corridor detrimental to the identity of the village and local economy. NHDC have not demonstrated how the infrastructure concerns will be met. The provisions for sites KB1-4 are wholly inadeauate.

Not justified as a better alternative is available West of Stevenage with less impact to residents across the district. Inconsistent with NPPF through allocation of significant contribution Green Belt land based on housing need alone.

Not a compliant process as changes to the NHDC documentation through the development of the draft through to submission versions has (a) excluded site KB4 until the last version and not properly included it (or the cumulative impact overall) in the modelling and assessment (b) changed the definition of Green Belt sites around Knebworth e.g. KB1 from significant to important without due reason in versions of the NHDC documents.

Not compliance as the Green Belt Review document has treated Knebworth as a town, whereas the Plan documents contradict this and treat is correctly as a Category A village. This leads to an housing over-allocation and under-assessment of the infrastructure availability.

Cumulative impact of KB1-4 plus adjacent Woolmer Green (150 houses) and Odyssey windfall (70 homes) is all known to NHDC since 2009 (see SHLAA 2009) and not considered in the Plan assessment of sites, infrastructure and its delivery. KB4 was also added in at the last minute and not assessed.

- Effects on the road infrastructure not determined. The traffic modelling assessment has excluded Knebworth and the B197 out of its scope and thus it is not adequate. The proposals in the plan (a new roundabout north of Knebworth) are wholly inadequate for the existing and planned capacity issues. Example photographs on a typical school weekday are attached to show London Road congestion.

- Ignored evidence of existing traffic congestion, this is publicly available for example from Google traffic statistical analysis. Whilst the Plan recognises the pinch point in the village centre, there are no solutions or analysis of the impact of the Plan.

- The harmful effects on the Conservation Areas through the obvious traffic patterns for the site access to KB1 and KB2, which have fundamental road restrictions which have not been assessed or considered in the site selection.

- lack of adequate schooling allocation / provision for the stated cumulative housing increases in Knebworth and immediate area including Woolmer Green and windfall

- lack of additional surgery allocation / provision for the stated cumulative housing increases in Knebworth and immediate area including Woolmer Green and windfall

- effect on the environment from and residents of KB1 and KB2 from citing homes and a primary school adjacent to the A1M, which is recognised as the most polluted and congested part of the entire motorway [ref. Highways England A1 East of England Strategic Study, June 2016].

- Effects on the local economy and village centre retail, contrary to policies SP4 and ETC2, via reallocation of site KB3 for housing only and not commercial use. In fact there is zero consideration of the local economy or retail in the Plan, despite these policies.

NHDC has deemed a threshold of 500 homes will trigger a need for a Strategic Policy. However Knebworth has 3 main sites split over only 2 landowners. There is a real risk of piecemeal development of the sites, which means that no single developer will address the fundamental infrastructure issues facing the village.

Neither justified, effective nor consistent with NPPF:
- Development would be contrary to government policy on Green Belt as set out in the NPPF. NHDC have not demonstrated that "exceptional circumstances" exist for the development of the site. Housing need alone is not a sufficient justification, as confirmed by the Minister of State in August 2016 in a letter to MPs.
- This particular tract of Green Belt is important because it prevents the encroachment of Knebworth into the countryside to the west.
- The site is located between the A1(M) and the western edge of Knebworth Village and is affected by traffic noise from the A1(M). The adjacent stretch of the A1(M), between Junction 6 and 7, is poorly-rated in the recent Highways England report (AI East of England Strategic Study, June 2016). There are high levels of congestion, accidents, and noise. The building of housing on this site would impact on the future viability of any plan to widen the A1(M). such a scheme cannot be ruled out, given that this section of the A1(M) is one of the most heaVily-congested in the UK.
- The amount of traffic generated by about 200 new dwellings would add considerably to the levels of traffic impacts on the B197. Congestion levels in the centre of the village would be exacerbated.
- There would also be pressures on the Deards Lane End Lane railway over-bridge, which is a Scheduled Ancient Monument. Increases in traffic are likely to have an adverse effect on the structural integrity of the bridge, which crosses the East Coast main railway line.
- To the east of the site is the Deards End Conservation Area, the character of which would be severely affected by the proximity of so much new housing and the increased levels of traffic. With a potential link to Park Road, and north-south movement through the village limited by three narrow railway bridges, there is a clear risk that a "rat run" would be created by drivers seeking to access Stevenage from both KB1 and KB2. Deards End Lane is a narrow single track road with no pavements, giving rise to safety concerns for all road users as well as pedestrians.
- The infrastructure improvements suggested by the District Council are impracticable. Any road widening would have an adverse effect on the character of the Conservation Area, and would involve the loss of residents' gardens.
- Potential effect on the Knebworth Woods SSSI, to the west of the proposed development, and an area of ancient woodland adjacent to the site. Both areas are protected habitats

Neither justified nor effective:
- Development would be contrary to government policy on Green Belt as set out in the NPPF. NHDC have not demonstrated that "exceptional circumstances" exist for the development of the site. Housing need alone is not a sufficient justification, as confirmed by the Minister of State in August 2016 in a letter to MPs.
- This particular tract of Green Belt is important because it prevents the encroachment of Knebworth into the countryside to the west.
- The site is located between the A1(M) and the western edge of Knebworth Village and is affected by traffic noise from the A1(M). The adjacent stretch of the A1(M), between Junction 6 and 7, is poorly-rated in the recent Highways England report (AI East of England Strategic Study, June 2016). There are high levels of congestion, accidents, and noise. The building of housing on this site would impact on the future viability of any plan to widen the A1(M). such a scheme cannot be ruled out, given that this section of the A1(M) is one of the most heaVily-congested in the UK.
- The amount of traffic generated by about 200 new dwellings would add considerably to the levels of traffic impacts on the B197. Congestion levels in the centre of the village would be exacerbated.
- A new primary school is proposed for this site. This is environmentally unacceptable as this means citing a primary school adjacent to the most polluted, congested and noisy part of the A1(M).
- There would also be pressures on the Deards Lane End Lane railway over-bridge, which is a Scheduled Ancient Monument. Increases in traffic are likely to have an adverse effect on the structural integrity of the bridge, which crosses the East Coast main railway line.
- Deards End Conservation Area and Stockers Green Conservation Areas are adjacent, the character of which would be severely affected by the proximity of so much new housing and the increased levels of traffic. With a potential link to Park Road, and north-south movement through the village limited by three narrow railway bridges, there is a clear risk that a "rat run" would be created by drivers seeking to access Stevenage of Welwyn Garden City from both KB1 and KB2. Deards End Lane and Gypsy Lane are narrow single track road in parts with no pavements, giving rise to safety concerns for all road users as well as pedestrians.
- The infrastructure improvements suggested by the District Council are impracticable. Any road widening would have an adverse effect on the character of the Conservation Areas, and would involve the loss of residents' gardens.
- Potential existing flooding concerns

It is neither justified not effective because:
- It would remove an important source of employment and business from the local economy.
- Proposed development of this site contravenes the District Council's own policy in the Local Plan, which seeks to protect employment on non-allocated sites as well as support village centre economies and retail use via SP4 and ETC2.
- Allocation for housing would actually reduce the amount of land zoned for commercial use in this part of the district
- The site is a key retail and commercial location in the centre of the village. In terms of its activity, it contributes much to the character of Knebworth. There is no analysis of justifiable alternatives in the Local Plan, to off-set the loss of this site to the local economy.

Neither justified nor effective:
- Development would be contrary to government policy on Green Belt as set out in the NPPF. NHDC have not demonstrated that "exceptional circumstances" exist for the development of the site. Housing need alone is not a sufficient justification, as confirmed by the Minister of State in August 2016 in a letter to MPs.
- This particular tract of Green Belt is significant because it prevents the encroachment of Knebworth into Stevenage to the north/east and Woolmer Green to the east/south.
- There is no firm plan for use of the site for education purposes despite comments in the plan suggesting such use, this requires addressing.
- The amount of traffic generated by about 200 new dwellings would add considerably to the levels of traffic impacts on the B197. Congestion levels in the centre of the village would be exacerbated.
- There are road infrastructure issues with Watton Road which need overcoming
- Potential existing flooding concerns