Local Plan 2011-2031 Proposed Submission Draft

I am writing to oppose the proposed submission by NHDC regarding the Local Plan 2011-2031 and in particular the sites identified for development in the village of Knebworth.

As a resident since 2009, a commuter into London and a local school mum using village roads, there are several reasons why I object, all based on personal experience as set out below.

SOUNDNESS

I do not consider that the plan has been based on a strategy which seeks to meet objectively assessed infrastructure requirements which are consistent with delivering and achieving sustainable developments. The road and rail network is already over-crowded for a village population of 2000. To increase the population by 33% without transport modelling to give evidence that NHDC can deliver improved and long term sustainable infrastructure improvements fails to meet basic requirements of both the plan and residents. Supported by the following cases:

* Knebworth's roads - the B197 is always used to by-pass the A1M in the event that the motorway is shut or has reduced lanes due to an accident. Traffic queues from as far back as Woolmer Green all the way through to Junction 7 by Knebworth Park (3 miles). The centre of Knebworth has time limited parking on both sides of the high street which restricts the width and often forces traffic to queue while vehicles use the high street in single file. The B197 is a main bus route and no consideration has been given to the impact of more commuters, either requiring additional bus services which will increase traffic flow or to the increased number of cars for 600+homes which will have the same effect. Access under the railway bridge by Knebworth station is single file and the footpath dangerously narrow underneath the bridge, particularly for parents with buggies who use that path often on the way to and from school. Swangley's Lane is a narrow country road with a sharp and dangerous bend just beyond Swangley's Farmhouse; there is no footpath along this road beyond Knebworth primary school. Watton Road (which I use four times a week for school runs) has speed bumps and only single file traffic due to residents parking on one side. Because Hertford Road was closed as a through road it has since forced traffic through Knebworth, specifically along Watton Road. Oakfields Road (where I live) is fully occupied by cars at weekends on one side of the road from visitors to the recreation ground when its car park is full (the recreation ground has two full size and two junior size football pitches used on both Saturdays and Sundays, 4 tennis courts, a playground, a basketball pitch and a bowling green). The village cannot sustain more traffic and there are no provisions for widening the roads.
* Rail services - there are only 2 trains an hour (except 3 during rush hour) but there is currently a proposal by Thameslink Govia to reduce the number of trains even further. I commute into London 4 days a week and will testify to already overcrowded trains which necessitate standing only during peak times. Knebworth has a significant commuter population, currently served by fast trains to/from King's Cross in peak times, but removing fast train services will lead to even more overcrowding and endanger public safety, even force out commuters from the district. An example of overcrowding is the 18.43 from King's Cross to Knebworth on 28/11/16. The train was not going to stop until St Neot's so commuters relocated to the departing 18.52. At Welwyn Garden City, where the 19.27 train divided from 8 to 4 carriages, a separate train ended service and the commuters piled on to the 19.27. Some could not get on. The train continued, 15 minutes late to Knebworth. This was not a one-off incident and since the line was assigned to Thameslink the service has deteriorated and is set to deteriorate further with fewer trains.
* Higher population will require more bus services. These will further reduce traffic through the village centre and along the B197 to Stevenage.

I do not consider the plan to be the most appropriate strategy when considered against reasonable alternatives.

* There is no evidence that the proposed 33% growth of Knebworth housing can be supported by the current infrastructure and absence of any transport modelling plans.
* GP surgery - it is already impossible to get a doctor's appointment at Knebworth Surgery on Station Road within 3 weeks, unless for an emergency. The surgery is over subscribed or under staffed and it is not possible to provide adequate services to additional residents of the village should the proposed developments go ahead. With the recent addition of a care home and retirement village in Knebworth I expect that home visits for the Knebworth Surgery GPs will only increase over time. The proposal for a surgery on the site of the existing library is for a replacement not an additional surgery and public health is therefore at significant risk from the proposals.
* Development of site KB4 would remove a vital wildlife habitat from a green belt area. The agricultural land is actively farmed all year round and living close to the fields I have first hand evidence of 2 to 3 crop rotations per year. The fields provide valuable and safe tracks for dog walkers and runners, something which surely must be considered given the absence of footpaths and high density traffic along several main roads in Knebworth.

I do not consider the plan to be deliverable based on effective joint working on cross boundary strategic priorities.
* There is no account in the plan of the need for highways, sufficient secondary and primary education facilities or health facilities to support the proposed development in Knebworth.
* There is no consideration given to educational needs, either for a secondary school for the current population (the nearest secondary school being Stevenage) or for an additional primary school. Class sizes at the primary school are already 30 with a dual-class entry in Reception. Facilities at Knebworth primary school are already over crowded and in need of modernising. Educational and PSHE requirements cannot be delivered in the absence of a sustainable educational plan for Knebworth's expansion.
* There may be a need to deliver housing by 2031 but the aggregate number of houses across all 4 proposed developments in Knebworth places enormous strain on a small village and significant risks to the existing and new communities.

LEGALITY

* KB4 has never been submitted before to the community as a site being considered for development. I do not think adequate pre-consultation work has been undertaken on this site and I believe the Council has failed to adhere to the legal compliance criteria as stated in the Council's Statement of Community Involvement.
* The National Planning Policy Framework states that local plans must be supported by local evidence base yet I do not consider the local needs to have been objectively assessed and, instead, to have been left unconsidered while the Council identifies potential sites in order to meet Government set housing quotas. There seems be no cooperation across local authorities with each developing local plans in isolation rather than collectively.

For all the reasons above I do not consider the local plan to be positively prepared, justified, effective or consistent with national policy and because of the detrimental and enormous impact it will have on Knebworth I wholeheartedly object to the proposal and feel it should be withdrawn.

I am writing to oppose the proposed submission by NHDC regarding the Local Plan 2011-2031 and in particular the sites identified for development in the village of Knebworth.

As a resident since 2009, a commuter into London and a local school mum using village roads, there are several reasons why I object, all based on personal experience as set out below.

SOUNDNESS

I do not consider that the plan has been based on a strategy which seeks to meet objectively assessed infrastructure requirements which are consistent with delivering and achieving sustainable developments. The road and rail network is already over-crowded for a village population of 2000. To increase the population by 33% without transport modelling to give evidence that NHDC can deliver improved and long term sustainable infrastructure improvements fails to meet basic requirements of both the plan and residents. Supported by the following cases:

* Knebworth's roads - the B197 is always used to by-pass the A1M in the event that the motorway is shut or has reduced lanes due to an accident. Traffic queues from as far back as Woolmer Green all the way through to Junction 7 by Knebworth Park (3 miles). The centre of Knebworth has time limited parking on both sides of the high street which restricts the width and often forces traffic to queue while vehicles use the high street in single file. The B197 is a main bus route and no consideration has been given to the impact of more commuters, either requiring additional bus services which will increase traffic flow or to the increased number of cars for 600+homes which will have the same effect. Access under the railway bridge by Knebworth station is single file and the footpath dangerously narrow underneath the bridge, particularly for parents with buggies who use that path often on the way to and from school. Swangley's Lane is a narrow country road with a sharp and dangerous bend just beyond Swangley's Farmhouse; there is no footpath along this road beyond Knebworth primary school. Watton Road (which I use four times a week for school runs) has speed bumps and only single file traffic due to residents parking on one side. Because Hertford Road was closed as a through road it has since forced traffic through Knebworth, specifically along Watton Road. Oakfields Road (where I live) is fully occupied by cars at weekends on one side of the road from visitors to the recreation ground when its car park is full (the recreation ground has two full size and two junior size football pitches used on both Saturdays and Sundays, 4 tennis courts, a playground, a basketball pitch and a bowling green). The village cannot sustain more traffic and there are no provisions for widening the roads.
* Rail services - there are only 2 trains an hour (except 3 during rush hour) but there is currently a proposal by Thameslink Govia to reduce the number of trains even further. I commute into London 4 days a week and will testify to already overcrowded trains which necessitate standing only during peak times. Knebworth has a significant commuter population, currently served by fast trains to/from King's Cross in peak times, but removing fast train services will lead to even more overcrowding and endanger public safety, even force out commuters from the district. An example of overcrowding is the 18.43 from King's Cross to Knebworth on 28/11/16. The train was not going to stop until St Neot's so commuters relocated to the departing 18.52. At Welwyn Garden City, where the 19.27 train divided from 8 to 4 carriages, a separate train ended service and the commuters piled on to the 19.27. Some could not get on. The train continued, 15 minutes late to Knebworth. This was not a one-off incident and since the line was assigned to Thameslink the service has deteriorated and is set to deteriorate further with fewer trains.
* Higher population will require more bus services. These will further reduce traffic through the village centre and along the B197 to Stevenage.

I do not consider the plan to be the most appropriate strategy when considered against reasonable alternatives.

* There is no evidence that the proposed 33% growth of Knebworth housing can be supported by the current infrastructure and absence of any transport modelling plans.
* GP surgery - it is already impossible to get a doctor's appointment at Knebworth Surgery on Station Road within 3 weeks, unless for an emergency. The surgery is over subscribed or under staffed and it is not possible to provide adequate services to additional residents of the village should the proposed developments go ahead. With the recent addition of a care home and retirement village in Knebworth I expect that home visits for the Knebworth Surgery GPs will only increase over time. The proposal for a surgery on the site of the existing library is for a replacement not an additional surgery and public health is therefore at significant risk from the proposals.
* Development of site KB4 would remove a vital wildlife habitat from a green belt area. The agricultural land is actively farmed all year round and living close to the fields I have first hand evidence of 2 to 3 crop rotations per year. The fields provide valuable and safe tracks for dog walkers and runners, something which surely must be considered given the absence of footpaths and high density traffic along several main roads in Knebworth.

I do not consider the plan to be deliverable based on effective joint working on cross boundary strategic priorities.
* There is no account in the plan of the need for highways, sufficient secondary and primary education facilities or health facilities to support the proposed development in Knebworth.
* There is no consideration given to educational needs, either for a secondary school for the current population (the nearest secondary school being Stevenage) or for an additional primary school. Class sizes at the primary school are already 30 with a dual-class entry in Reception. Facilities at Knebworth primary school are already over crowded and in need of modernising. Educational and PSHE requirements cannot be delivered in the absence of a sustainable educational plan for Knebworth's expansion.
* There may be a need to deliver housing by 2031 but the aggregate number of houses across all 4 proposed developments in Knebworth places enormous strain on a small village and significant risks to the existing and new communities.

LEGALITY

* KB4 has never been submitted before to the community as a site being considered for development. I do not think adequate pre-consultation work has been undertaken on this site and I believe the Council has failed to adhere to the legal compliance criteria as stated in the Council's Statement of Community Involvement.
* The National Planning Policy Framework states that local plans must be supported by local evidence base yet I do not consider the local needs to have been objectively assessed and, instead, to have been left unconsidered while the Council identifies potential sites in order to meet Government set housing quotas. There seems be no cooperation across local authorities with each developing local plans in isolation rather than collectively.

For all the reasons above I do not consider the local plan to be positively prepared, justified, effective or consistent with national policy and because of the detrimental and enormous impact it will have on Knebworth I wholeheartedly object to the proposal and feel it should be withdrawn.