Local Plan 2011-2031 Proposed Submission Draft

The draft Plan is neither positively prepared nor fully justified, as it proposes the erosion of, and development on, a significant amount of Green Belt, for a housing requirement based on unsound data. The draft Plan does not consider a number of potential alternative brownfield sites, nor housing development sites recently approved. Furthermore, the estimate of future housing requirement has been reached from the Strategic Housing Market Assessment, which was prepared before the EU Referendum vote and does not consider the resulting effect of reducing immigration. It therefore does not demonstrate sufficient need to justify removing Green Belt.

Sites KB1, KB2 and KB4 propose a cumulative total of 584 dwellings, which results in a 31% increase in the size of the village and exceeds the threshold requirement for a specific Strategic Policy (SP). There is no SP in Section 4 for Knebworth and therefore the impact of housing development on this Category A village has not been properly considered, and is in conflict with the NPPF.

This site already forms part of an "appropriate, defensible Green Belt boundary" and its reclassification for housing development is unjustified, owing to improper consideration of the environmental impact and poor accessibility. Development will damage the character of the Deards End Conservation Area and will potentially harm species in Knebworth Woods SSSI and the adjacent priority habitat. Furthermore, the existing Deards End Lane access road is insufficient to support increased traffic from new housing and cannot be widened owing to railway bridge and existing properties.

The size and density of the KB2 proposed site is not sustainable and insufficient consideration has been given to its environmental impact and accessibility. The site already forms an "appropriate, defensible Green Belt boundary" between Knebworth and the A1(M) motorway, which would be removed by this development. It also suffers from significant existing surface water flooding, including any run-off from the A1(M) which would increase after the proposed widening of the carriageway. Road access to the KB2 site is limited and difficult to expand, as it will create congestion at the insurmountable obstacle of the narrow railway bridge at Gun Lane. Furthermore, development of KB2 risks damaging the architectural and historic character of the adjacent Stockens Green Conservation Area, and extends the South and West boundaries of Knebworth risking coalescence with the neighbouring hamlet of Potters Heath.