Local Plan 2011-2031 Proposed Submission Draft

This site with a proposal for 227 dwellings is the most sensitive for development as it is an area of great landscape value and has the highest point in Knebworth village at the Black Pits pond. The NHDC Land Sensitivity and Capacity Study Report - Planning Policy and Projects, November 2006 identified only three Knebworth sites with low sensitivity and high capacity. In each of the three cases the report states "these sites have been appraised as being able to accommodate new housing development without significant effects on their character or the surrounding landscape." KB1 is not one of these sites.

The NHDC Land Allocations - Additional Suggested Sites July, 2009 highlighted the site's weaknesses as:

i. Green field site as grade 3 agricultural land

ii. Adjoins a conservation area

iii. Site is groundwater source protection zone 2

iv. Site is located next to the A1M

v. Identified constraints on utilities and capacity of primary school

Council's weakness iv above has recently been reinforced by the Department for Transport in their A1 East of England strategic study: interim report of August 2016 which concluded, inter alia, that parts of the A1 are located unacceptably close to residential locations, causing unpleasant environmental conditions for local residents. It is hard to understand how moving Knebworth closer to the A1(M) is consistent with this very recent government finding.

The site has a mature hedge and tree line running north to south across the high point abounds with wildlife. In summary the site has the capacity for new dwellings but no other attributes and would be a highly visible ugly 'carbuncle' between the conservation area and the A1M.

My objection to the Plan is the failure of the Council to justify a long series of proposals for the removal of land from the Green Belt around towns and villages. Such justification should have specifically included the demonstration by the Council of the 'exceptional circumstances' for removing land from the Green Belt on a site by site, and settlement by settlement basis, and setting them out in the Plan. Instead, the Council appears to have relied on a blanket assumption that all housing and other development needs, not just in the District but in Stevenage and Luton as well, identified through their background studies, must be met in full, despite national planning policy and planning case law to the contrary. If the Plan is allowed to proceed as published by the Council, it would commit future generations to continuing development which would cause incalculable harm to the Green Belt.

I believe that the Council has not considered all reasonable alternative approaches to meeting the District's development needs, particularly when setting a Housing Target, and that this failure has contributed to an unsound Strategy. A realistic contribution to housing capacity from a greater range of sources including windfall sites, changes of use in accordance with current permitted development rights, and other measures promoting the recycling of previously developed land and property, should have been included in the Plan, and a Housing Target then determined that reflects both development needs and the nationally important constraints that exist in this part of Hertfordshire.

The proposal to move Green Belt boundaries from their current long established position solely because there is an equally or more defensible location elsewhere is contrary to national Green Belt policy. The stated reason for doing so is not an exceptional circumstance, and is not justified. The removal of Green Belt status from the land affected would be likely to cause significant harm to the Green Belt and it's overall purpose.

My objection to the Plan is the failure of the Council to justify a long series of proposals for the removal of land from the Green Belt around towns and villages. Such justification should have specifically included the demonstration by the Council of the 'exceptional circumstances' for removing land from the Green Belt on a site by site, and settlement by settlement basis, and setting them out in the Plan. Instead, the Council appears to have relied on a blanket assumption that all housing and other development needs, not just in the District but in Stevenage and Luton as well, identified through their background studies, must be met in full, despite national planning policy and planning case law to the contrary. If the Plan is allowed to proceed as published by the Council, it would commit future generations to continuing development which would cause incalculable harm to the Green Belt.

I believe that the Council has not considered all reasonable alternative approaches to meeting the District's development needs, particularly when setting a Housing Target, and that this failure has contributed to an unsound Strategy. A realistic contribution to housing capacity from a greater range of sources including windfall sites, changes of use in accordance with current permitted development rights, and other measures promoting the recycling of previously developed land and property, should have been included in the Plan, and a Housing Target then determined that reflects both development needs and the nationally important constraints that exist in this part of Hertfordshire.

The proposal to move Green Belt boundaries from their current long established position solely because there is an equally or more defensible location elsewhere is contrary to national Green Belt policy. The stated reason for doing so is not an exceptional circumstance, and is not justified. The removal of Green Belt status from the land affected would be likely to cause significant harm to the Green Belt and it's overall purpose.

This site with a proposal for approximately 200 dwellings is sensitive for development.

The NHDC Land Allocations - Additional Suggested Sites July, 2009 highlighted the site's weaknesses as:

i. Green field site as grade 3 agricultural land

ii. Adjoins a conservation area

iii. Site is groundwater source protection zone 3

iv. Site is located next to the A1M

v. Identified constraints on utilities and capacity of primary school

vi. Flooding in the adjoining Wimpey estate has also occurred this past winter

Council's weakness iv above has recently been reinforced by the Department for Transport in their A1 East of England strategic study: interim report of August 2016 which concluded, inter alia, that parts of the A1 are located unacceptably close to residential locations, causing unpleasant environmental conditions for local residents. It is hard to understand how moving Knebworth closer to the A1(M) is consistent with this very recent government finding.

In summary the site has the capacity for new dwellings but no other attributes.

This site with a proposal for approximately 200 dwellings is a sensitive site for development. The NHDC Land Sensitivity and Capacity Study Report - Planning Policy and Projects, November 2006 identified only three Knebworth sites with low sensitivity and high capacity. In each of the three cases the report states "these sites have been appraised as being able to accommodate new housing development without significant effects on their character or the surrounding landscape." KB4 is not one of these sites.

The NHDC Land Allocations - Additional Suggested Sites July, 2009 highlighted the site's weaknesses as:

i. Green field site as grade 3 agricultural land

ii. Site in groundwater protection zones 1 and 2

iii. Identified constraints on utilities and capacity of primary school.