Local Plan 2011-2031 Proposed Submission Draft

Economic Factors:
Point 1.7 of the LP confirms the aim to 'protect existing Green Belt and only alter it in exceptional circumstances'. In order for a housing development to be considered 'exceptional circumstances' I would argue that provision must be outlined in the LP for affordable housing schemes. The local plan suggests that 'homes must address the impact they may have on the environment and most of all meet the needs of our local population including ensuring that our families can afford to live here and that the right type of homes are provided for them'
As there has been a 20% rise in house prices over the last two years affordable housing in North Hertfordshire is a serious issue, with the average house price in the district 'well above the regional and national averages' as highlighted in point 2.22 of the LP. With 'currently more than 1,600 households on the local authority housing register awaiting assistance with their housing needs' it is an oversight for the LP to fail to include a guarantee of provision to meet these needs and therefore justify the exceptional circumstances of building on the Green Belt. The LP acknowledges the 'need for more affordable housing' but makes no attempt to confirm that affordable housing or social housing will be assured within the new developments.
Environmental Factors:
Key environmental factors in the Knebworth development sites refer to preservation of green belt land and aesthetics, as well as mitigation of drainage strategy in existing surface water flood risk issues. As there are several types of Sustainable Urban Drainage Systems, the LP should be revised to outline which systems will be put in place for sites KB1 and KB2 so a proper assessment of environmental impact can be undertaken.
According to the NHDC Green Belt Review, listed as supporting evidence for the LP, the Green Belt along the A1(M) corridor to the south of Stevenage 'plays an important role in preventing sprawl' which was of course one of the primary reasons for setting up the Green Belt. It should be considered that 2 of the development sites, KB1 and KB2 are proposed for building on this specific stretch of Green Belt land. The finding of the review states that the Green Belt along the A1(M) corridor 'overall makes a significant contribution to Green Belt purposes, helping to prevent sprawl, merger and encroachment' and therefore the development on this land should be fully justified as extraordinary circumstances in the LP. The Green Belt separating Stevenage and Knebworth performs a significant function, as opposed to the Green Belt to the east of Luton which currently performs a limited function in terms of the preventing the merger of towns;. With the development of site KB1, Knebworth and Stevenage will be separated by the Private Golf club only, leaving the separation of Knebworth and Stevenage tenuous.
Transport and Congestion Infrastructure:
The LP does not go into much detail on the provision of transport infrastructure despite point 2.76 acknowledging that 'The District has a considerable daily outflow of commuters, to highly skilled employment areas mainly in central London'. I would like to enquire as to whether the LP will be revised if the proposed changes to Great Northern Rail provision between Cambridge/London and Peterborough/London as the reduction in services stopping at Knebworth at peak times will have a severe impact on overcrowding at Knebworth Station for commuters. Growth in commuters by train has increased by 71% in the last decade compared with a 48% increase in Hitchin and Letchworth. The addition of 600 new homes in Knebworth would also increase the number of rail users and contribute to overcrowding on services. The LP states that investment plans of key infrastructures and utilities providers including Network Rail, Highways England and Thames Water' have been taken into account but the proposed changes to rail services affecting Knebworth from 2018 has not been acknowledged in the LP.
I notice that clause 13.195 of the LP states 'Our transport modelling does not identify any specific mitigation scheme requirements for Knebworth.' This is an extreme oversight as several roads in Knebworth already experience congestion and an increase in population will exacerbate this. Most notably, the high street which has been acknowledged in the LP as a 'pinch point, particularly when delays or incidents on the A1(M) result in the B197 being used as an alternate route'. However, no change to transport infrastructure has been outlined in the LP. Whilst I understand the point made in 13.197 that 'Highway management measures, such as the use of Traffic Regulation Orders (TROs), lie outside the direct control of the planning system and it is therefore not for this Local Plan to dictate the most appropriate solution(s).' I believe exploration into possibilities before the LP is approved is important. In particular, the provision for 14 homes on the KB3 site directly located on the village high street will increase congestion in that area and has not been addressed by the local plan.
Additionally, the LP acknowledges the transportation infrastructure issues surrounding sites KB1 and KB2 in relation to the Deards End Lane Railway Bridge, a scheduled Ancient Monument that is often too narrow for two vehicles to pass at the same time. The additional almost 400 houses in sites KB1 and KB2 will increase Deards End Lane traffic heavily as an access route into Stevenage if additional roads are not constructed to draw traffic away from Deards End Lane and Gypsy Lane near sites KB1 and KB2, and the LP currently makes no mention of action to be taken on these points.
In addition, point 13.199 indicates that 'Sites in Knebworth will need to ensure that any transport assessments appropriately take these issues into account and contribute reasonably to any necessary mitigation measures'. With Deards End Lane Railway Bridge being a Scheduled Ancient Monument, will plans for other routes into Stevenage that avoid Deards End Lane and Gypsy Lane be considered?
As the LP refers to the NHDC Infrastructure Delivery Plan September 2016 as a representation of the LP for infrastructure, it is necessary to note that the Local Transport Plan 3 encourages 'support for new development to be sited and designed so that maximum use can be made of sustainable modes, including bus travel, in order to access services'. The Infrastructure delivery plan also acknowledges that local bus services are 'patchy in rural areas', running infrequently in Knebworth. The proposed new developments would put further strain on bus services to and from the village. There being 'no specific proposals or funding' for a mitigation scheme for Knebworth transport despite 'existing highway issues - for instance in Knebworth' is a major oversight in the LP and a barrier to resident acceptance of the plan.
The LP acknowledges that it will be necessary to 'work with the Highway Authority when taking forward the development sites set out in the Local Plan. Work on the next iteration of the LTP -the 2050 Transport Vision- is well underway and expected to be finalized by the end of 2016' It is impossible for residents of Knebworth to respond to transport infrastructure issues until the next iteration of the LTP has been released, and I therefore suggest the period of consultation should be extended until after the release of this plan.
Logistic and Location Factors:
The LP references the Statement of Community as reason for easing the 'unmet needs from Luton'. Whilst the developments in North Herts arguably have the space to accommodate this need, it may not be logistically sound. If demand for housing in Luton is high, this suggests people already working in Luton and surrounding areas are driving the demand. With the LP's already acknowledged that 'no rail links from the District to the west exist, meaning towns like Luton and Milton Keynes are less accessible via public transport'. This would put additional strain on road traffic and already strained bus services as those commuting West into Luton and surrounding areas will be forced to commute by car.
GP and Health Services Provision:
Currently the Knebworth Medical Practice has 33 patients per square meter with absolutely no spare capacity for additional patients. This contrasts with the relatively lower patients per square meter in Hitchin and parts of Letchworth. Considering best practice principles suggest that 'the number of registered patients at that practice should not exceed a density of 20 patients per square metre' there is clear evidence that the Knebworth Medical Practice cannot be expected to cope with additional patients. The LP presents that 'an application has recently been submitted for a new library, doctors surgery and pharmacy on the site of the current library' but makes no further mention of this. I suggest that the LP should make provision for these facilities to be approved prior to the plan being accepted, as should the application for these facilities be declined; the village would not be able to cope with the new developments of the LP.
Waste Water:
In the NHDC Infrastructure Delivery Plan, Thames Water's evaluation of sewerage capacity for Knebworth suggests 'Further consideration of sewerage capacity needed and issues with the foul sewer system needs reviewing as the village does not have a dedicated surface water system.'

Economic Factors:
Point 1.7 of the LP confirms the aim to 'protect existing Green Belt and only alter it in exceptional circumstances'. In order for a housing development to be considered 'exceptional circumstances' I would argue that provision must be outlined in the LP for affordable housing schemes. The local plan suggests that 'homes must address the impact they may have on the environment and most of all meet the needs of our local population including ensuring that our families can afford to live here and that the right type of homes are provided for them'
As there has been a 20% rise in house prices over the last two years affordable housing in North Hertfordshire is a serious issue, with the average house price in the district 'well above the regional and national averages' as highlighted in point 2.22 of the LP. With 'currently more than 1,600 households on the local authority housing register awaiting assistance with their housing needs' it is an oversight for the LP to fail to include a guarantee of provision to meet these needs and therefore justify the exceptional circumstances of building on the Green Belt. The LP acknowledges the 'need for more affordable housing' but makes no attempt to confirm that affordable housing or social housing will be assured within the new developments.
Environmental Factors:
Key environmental factors in the Knebworth development sites refer to preservation of green belt land and aesthetics, as well as mitigation of drainage strategy in existing surface water flood risk issues. As there are several types of Sustainable Urban Drainage Systems, the LP should be revised to outline which systems will be put in place for sites KB1 and KB2 so a proper assessment of environmental impact can be undertaken.
According to the NHDC Green Belt Review, listed as supporting evidence for the LP, the Green Belt along the A1(M) corridor to the south of Stevenage 'plays an important role in preventing sprawl' which was of course one of the primary reasons for setting up the Green Belt. It should be considered that 2 of the development sites, KB1 and KB2 are proposed for building on this specific stretch of Green Belt land. The finding of the review states that the Green Belt along the A1(M) corridor 'overall makes a significant contribution to Green Belt purposes, helping to prevent sprawl, merger and encroachment' and therefore the development on this land should be fully justified as extraordinary circumstances in the LP. The Green Belt separating Stevenage and Knebworth performs a significant function, as opposed to the Green Belt to the east of Luton which currently performs a limited function in terms of the preventing the merger of towns;. With the development of site KB1, Knebworth and Stevenage will be separated by the Private Golf club only, leaving the separation of Knebworth and Stevenage tenuous.
Transport and Congestion Infrastructure:
The LP does not go into much detail on the provision of transport infrastructure despite point 2.76 acknowledging that 'The District has a considerable daily outflow of commuters, to highly skilled employment areas mainly in central London'. I would like to enquire as to whether the LP will be revised if the proposed changes to Great Northern Rail provision between Cambridge/London and Peterborough/London as the reduction in services stopping at Knebworth at peak times will have a severe impact on overcrowding at Knebworth Station for commuters. Growth in commuters by train has increased by 71% in the last decade compared with a 48% increase in Hitchin and Letchworth. The addition of 600 new homes in Knebworth would also increase the number of rail users and contribute to overcrowding on services. The LP states that investment plans of key infrastructures and utilities providers including Network Rail, Highways England and Thames Water' have been taken into account but the proposed changes to rail services affecting Knebworth from 2018 has not been acknowledged in the LP.
I notice that clause 13.195 of the LP states 'Our transport modelling does not identify any specific mitigation scheme requirements for Knebworth.' This is an extreme oversight as several roads in Knebworth already experience congestion and an increase in population will exacerbate this. Most notably, the high street which has been acknowledged in the LP as a 'pinch point, particularly when delays or incidents on the A1(M) result in the B197 being used as an alternate route'. However, no change to transport infrastructure has been outlined in the LP. Whilst I understand the point made in 13.197 that 'Highway management measures, such as the use of Traffic Regulation Orders (TROs), lie outside the direct control of the planning system and it is therefore not for this Local Plan to dictate the most appropriate solution(s).' I believe exploration into possibilities before the LP is approved is important. In particular, the provision for 14 homes on the KB3 site directly located on the village high street will increase congestion in that area and has not been addressed by the local plan.
Additionally, the LP acknowledges the transportation infrastructure issues surrounding sites KB1 and KB2 in relation to the Deards End Lane Railway Bridge, a scheduled Ancient Monument that is often too narrow for two vehicles to pass at the same time. The additional almost 400 houses in sites KB1 and KB2 will increase Deards End Lane traffic heavily as an access route into Stevenage if additional roads are not constructed to draw traffic away from Deards End Lane and Gypsy Lane near sites KB1 and KB2, and the LP currently makes no mention of action to be taken on these points.
In addition, point 13.199 indicates that 'Sites in Knebworth will need to ensure that any transport assessments appropriately take these issues into account and contribute reasonably to any necessary mitigation measures'. With Deards End Lane Railway Bridge being a Scheduled Ancient Monument, will plans for other routes into Stevenage that avoid Deards End Lane and Gypsy Lane be considered?
As the LP refers to the NHDC Infrastructure Delivery Plan September 2016 as a representation of the LP for infrastructure, it is necessary to note that the Local Transport Plan 3 encourages 'support for new development to be sited and designed so that maximum use can be made of sustainable modes, including bus travel, in order to access services'. The Infrastructure delivery plan also acknowledges that local bus services are 'patchy in rural areas', running infrequently in Knebworth. The proposed new developments would put further strain on bus services to and from the village. There being 'no specific proposals or funding' for a mitigation scheme for Knebworth transport despite 'existing highway issues - for instance in Knebworth' is a major oversight in the LP and a barrier to resident acceptance of the plan.
The LP acknowledges that it will be necessary to 'work with the Highway Authority when taking forward the development sites set out in the Local Plan. Work on the next iteration of the LTP -the 2050 Transport Vision- is well underway and expected to be finalized by the end of 2016' It is impossible for residents of Knebworth to respond to transport infrastructure issues until the next iteration of the LTP has been released, and I therefore suggest the period of consultation should be extended until after the release of this plan.
Logistic and Location Factors:
The LP references the Statement of Community as reason for easing the 'unmet needs from Luton'. Whilst the developments in North Herts arguably have the space to accommodate this need, it may not be logistically sound. If demand for housing in Luton is high, this suggests people already working in Luton and surrounding areas are driving the demand. With the LP's already acknowledged that 'no rail links from the District to the west exist, meaning towns like Luton and Milton Keynes are less accessible via public transport'. This would put additional strain on road traffic and already strained bus services as those commuting West into Luton and surrounding areas will be forced to commute by car.
GP and Health Services Provision:
Currently the Knebworth Medical Practice has 33 patients per square meter with absolutely no spare capacity for additional patients. This contrasts with the relatively lower patients per square meter in Hitchin and parts of Letchworth. Considering best practice principles suggest that 'the number of registered patients at that practice should not exceed a density of 20 patients per square metre' there is clear evidence that the Knebworth Medical Practice cannot be expected to cope with additional patients. The LP presents that 'an application has recently been submitted for a new library, doctors surgery and pharmacy on the site of the current library' but makes no further mention of this. I suggest that the LP should make provision for these facilities to be approved prior to the plan being accepted, as should the application for these facilities be declined; the village would not be able to cope with the new developments of the LP.
Waste Water:
In the NHDC Infrastructure Delivery Plan, Thames Water's evaluation of sewerage capacity for Knebworth suggests 'Further consideration of sewerage capacity needed and issues with the foul sewer system needs reviewing as the village does not have a dedicated surface water system.'

Economic Factors:
Point 1.7 of the LP confirms the aim to 'protect existing Green Belt and only alter it in exceptional circumstances'. In order for a housing development to be considered 'exceptional circumstances' I would argue that provision must be outlined in the LP for affordable housing schemes. The local plan suggests that 'homes must address the impact they may have on the environment and most of all meet the needs of our local population including ensuring that our families can afford to live here and that the right type of homes are provided for them'
As there has been a 20% rise in house prices over the last two years affordable housing in North Hertfordshire is a serious issue, with the average house price in the district 'well above the regional and national averages' as highlighted in point 2.22 of the LP. With 'currently more than 1,600 households on the local authority housing register awaiting assistance with their housing needs' it is an oversight for the LP to fail to include a guarantee of provision to meet these needs and therefore justify the exceptional circumstances of building on the Green Belt. The LP acknowledges the 'need for more affordable housing' but makes no attempt to confirm that affordable housing or social housing will be assured within the new developments.
Environmental Factors:
Key environmental factors in the Knebworth development sites refer to preservation of green belt land and aesthetics, as well as mitigation of drainage strategy in existing surface water flood risk issues. As there are several types of Sustainable Urban Drainage Systems, the LP should be revised to outline which systems will be put in place for sites KB1 and KB2 so a proper assessment of environmental impact can be undertaken.
According to the NHDC Green Belt Review, listed as supporting evidence for the LP, the Green Belt along the A1(M) corridor to the south of Stevenage 'plays an important role in preventing sprawl' which was of course one of the primary reasons for setting up the Green Belt. It should be considered that 2 of the development sites, KB1 and KB2 are proposed for building on this specific stretch of Green Belt land. The finding of the review states that the Green Belt along the A1(M) corridor 'overall makes a significant contribution to Green Belt purposes, helping to prevent sprawl, merger and encroachment' and therefore the development on this land should be fully justified as extraordinary circumstances in the LP. The Green Belt separating Stevenage and Knebworth performs a significant function, as opposed to the Green Belt to the east of Luton which currently performs a limited function in terms of the preventing the merger of towns;. With the development of site KB1, Knebworth and Stevenage will be separated by the Private Golf club only, leaving the separation of Knebworth and Stevenage tenuous.
Transport and Congestion Infrastructure:
The LP does not go into much detail on the provision of transport infrastructure despite point 2.76 acknowledging that 'The District has a considerable daily outflow of commuters, to highly skilled employment areas mainly in central London'. I would like to enquire as to whether the LP will be revised if the proposed changes to Great Northern Rail provision between Cambridge/London and Peterborough/London as the reduction in services stopping at Knebworth at peak times will have a severe impact on overcrowding at Knebworth Station for commuters. Growth in commuters by train has increased by 71% in the last decade compared with a 48% increase in Hitchin and Letchworth. The addition of 600 new homes in Knebworth would also increase the number of rail users and contribute to overcrowding on services. The LP states that investment plans of key infrastructures and utilities providers including Network Rail, Highways England and Thames Water' have been taken into account but the proposed changes to rail services affecting Knebworth from 2018 has not been acknowledged in the LP.
I notice that clause 13.195 of the LP states 'Our transport modelling does not identify any specific mitigation scheme requirements for Knebworth.' This is an extreme oversight as several roads in Knebworth already experience congestion and an increase in population will exacerbate this. Most notably, the high street which has been acknowledged in the LP as a 'pinch point, particularly when delays or incidents on the A1(M) result in the B197 being used as an alternate route'. However, no change to transport infrastructure has been outlined in the LP. Whilst I understand the point made in 13.197 that 'Highway management measures, such as the use of Traffic Regulation Orders (TROs), lie outside the direct control of the planning system and it is therefore not for this Local Plan to dictate the most appropriate solution(s).' I believe exploration into possibilities before the LP is approved is important. In particular, the provision for 14 homes on the KB3 site directly located on the village high street will increase congestion in that area and has not been addressed by the local plan.
Additionally, the LP acknowledges the transportation infrastructure issues surrounding sites KB1 and KB2 in relation to the Deards End Lane Railway Bridge, a scheduled Ancient Monument that is often too narrow for two vehicles to pass at the same time. The additional almost 400 houses in sites KB1 and KB2 will increase Deards End Lane traffic heavily as an access route into Stevenage if additional roads are not constructed to draw traffic away from Deards End Lane and Gypsy Lane near sites KB1 and KB2, and the LP currently makes no mention of action to be taken on these points.
In addition, point 13.199 indicates that 'Sites in Knebworth will need to ensure that any transport assessments appropriately take these issues into account and contribute reasonably to any necessary mitigation measures'. With Deards End Lane Railway Bridge being a Scheduled Ancient Monument, will plans for other routes into Stevenage that avoid Deards End Lane and Gypsy Lane be considered?
As the LP refers to the NHDC Infrastructure Delivery Plan September 2016 as a representation of the LP for infrastructure, it is necessary to note that the Local Transport Plan 3 encourages 'support for new development to be sited and designed so that maximum use can be made of sustainable modes, including bus travel, in order to access services'. The Infrastructure delivery plan also acknowledges that local bus services are 'patchy in rural areas', running infrequently in Knebworth. The proposed new developments would put further strain on bus services to and from the village. There being 'no specific proposals or funding' for a mitigation scheme for Knebworth transport despite 'existing highway issues - for instance in Knebworth' is a major oversight in the LP and a barrier to resident acceptance of the plan.
The LP acknowledges that it will be necessary to 'work with the Highway Authority when taking forward the development sites set out in the Local Plan. Work on the next iteration of the LTP -the 2050 Transport Vision- is well underway and expected to be finalized by the end of 2016' It is impossible for residents of Knebworth to respond to transport infrastructure issues until the next iteration of the LTP has been released, and I therefore suggest the period of consultation should be extended until after the release of this plan.
Logistic and Location Factors:
The LP references the Statement of Community as reason for easing the 'unmet needs from Luton'. Whilst the developments in North Herts arguably have the space to accommodate this need, it may not be logistically sound. If demand for housing in Luton is high, this suggests people already working in Luton and surrounding areas are driving the demand. With the LP's already acknowledged that 'no rail links from the District to the west exist, meaning towns like Luton and Milton Keynes are less accessible via public transport'. This would put additional strain on road traffic and already strained bus services as those commuting West into Luton and surrounding areas will be forced to commute by car.
GP and Health Services Provision:
Currently the Knebworth Medical Practice has 33 patients per square meter with absolutely no spare capacity for additional patients. This contrasts with the relatively lower patients per square meter in Hitchin and parts of Letchworth. Considering best practice principles suggest that 'the number of registered patients at that practice should not exceed a density of 20 patients per square metre' there is clear evidence that the Knebworth Medical Practice cannot be expected to cope with additional patients. The LP presents that 'an application has recently been submitted for a new library, doctors surgery and pharmacy on the site of the current library' but makes no further mention of this. I suggest that the LP should make provision for these facilities to be approved prior to the plan being accepted, as should the application for these facilities be declined; the village would not be able to cope with the new developments of the LP.
Waste Water:
In the NHDC Infrastructure Delivery Plan, Thames Water's evaluation of sewerage capacity for Knebworth suggests 'Further consideration of sewerage capacity needed and issues with the foul sewer system needs reviewing as the village does not have a dedicated surface water system.'

Economic Factors:
Point 1.7 of the LP confirms the aim to 'protect existing Green Belt and only alter it in exceptional circumstances'. In order for a housing development to be considered 'exceptional circumstances' I would argue that provision must be outlined in the LP for affordable housing schemes. The local plan suggests that 'homes must address the impact they may have on the environment and most of all meet the needs of our local population including ensuring that our families can afford to live here and that the right type of homes are provided for them'
As there has been a 20% rise in house prices over the last two years affordable housing in North Hertfordshire is a serious issue, with the average house price in the district 'well above the regional and national averages' as highlighted in point 2.22 of the LP. With 'currently more than 1,600 households on the local authority housing register awaiting assistance with their housing needs' it is an oversight for the LP to fail to include a guarantee of provision to meet these needs and therefore justify the exceptional circumstances of building on the Green Belt. The LP acknowledges the 'need for more affordable housing' but makes no attempt to confirm that affordable housing or social housing will be assured within the new developments.
Environmental Factors:
Key environmental factors in the Knebworth development sites refer to preservation of green belt land and aesthetics, as well as mitigation of drainage strategy in existing surface water flood risk issues. As there are several types of Sustainable Urban Drainage Systems, the LP should be revised to outline which systems will be put in place for sites KB1 and KB2 so a proper assessment of environmental impact can be undertaken.
According to the NHDC Green Belt Review, listed as supporting evidence for the LP, the Green Belt along the A1(M) corridor to the south of Stevenage 'plays an important role in preventing sprawl' which was of course one of the primary reasons for setting up the Green Belt. It should be considered that 2 of the development sites, KB1 and KB2 are proposed for building on this specific stretch of Green Belt land. The finding of the review states that the Green Belt along the A1(M) corridor 'overall makes a significant contribution to Green Belt purposes, helping to prevent sprawl, merger and encroachment' and therefore the development on this land should be fully justified as extraordinary circumstances in the LP. The Green Belt separating Stevenage and Knebworth performs a significant function, as opposed to the Green Belt to the east of Luton which currently performs a limited function in terms of the preventing the merger of towns;. With the development of site KB1, Knebworth and Stevenage will be separated by the Private Golf club only, leaving the separation of Knebworth and Stevenage tenuous.
Transport and Congestion Infrastructure:
The LP does not go into much detail on the provision of transport infrastructure despite point 2.76 acknowledging that 'The District has a considerable daily outflow of commuters, to highly skilled employment areas mainly in central London'. I would like to enquire as to whether the LP will be revised if the proposed changes to Great Northern Rail provision between Cambridge/London and Peterborough/London as the reduction in services stopping at Knebworth at peak times will have a severe impact on overcrowding at Knebworth Station for commuters. Growth in commuters by train has increased by 71% in the last decade compared with a 48% increase in Hitchin and Letchworth. The addition of 600 new homes in Knebworth would also increase the number of rail users and contribute to overcrowding on services. The LP states that investment plans of key infrastructures and utilities providers including Network Rail, Highways England and Thames Water' have been taken into account but the proposed changes to rail services affecting Knebworth from 2018 has not been acknowledged in the LP.
I notice that clause 13.195 of the LP states 'Our transport modelling does not identify any specific mitigation scheme requirements for Knebworth.' This is an extreme oversight as several roads in Knebworth already experience congestion and an increase in population will exacerbate this. Most notably, the high street which has been acknowledged in the LP as a 'pinch point, particularly when delays or incidents on the A1(M) result in the B197 being used as an alternate route'. However, no change to transport infrastructure has been outlined in the LP. Whilst I understand the point made in 13.197 that 'Highway management measures, such as the use of Traffic Regulation Orders (TROs), lie outside the direct control of the planning system and it is therefore not for this Local Plan to dictate the most appropriate solution(s).' I believe exploration into possibilities before the LP is approved is important. In particular, the provision for 14 homes on the KB3 site directly located on the village high street will increase congestion in that area and has not been addressed by the local plan.
Additionally, the LP acknowledges the transportation infrastructure issues surrounding sites KB1 and KB2 in relation to the Deards End Lane Railway Bridge, a scheduled Ancient Monument that is often too narrow for two vehicles to pass at the same time. The additional almost 400 houses in sites KB1 and KB2 will increase Deards End Lane traffic heavily as an access route into Stevenage if additional roads are not constructed to draw traffic away from Deards End Lane and Gypsy Lane near sites KB1 and KB2, and the LP currently makes no mention of action to be taken on these points.
In addition, point 13.199 indicates that 'Sites in Knebworth will need to ensure that any transport assessments appropriately take these issues into account and contribute reasonably to any necessary mitigation measures'. With Deards End Lane Railway Bridge being a Scheduled Ancient Monument, will plans for other routes into Stevenage that avoid Deards End Lane and Gypsy Lane be considered?
As the LP refers to the NHDC Infrastructure Delivery Plan September 2016 as a representation of the LP for infrastructure, it is necessary to note that the Local Transport Plan 3 encourages 'support for new development to be sited and designed so that maximum use can be made of sustainable modes, including bus travel, in order to access services'. The Infrastructure delivery plan also acknowledges that local bus services are 'patchy in rural areas', running infrequently in Knebworth. The proposed new developments would put further strain on bus services to and from the village. There being 'no specific proposals or funding' for a mitigation scheme for Knebworth transport despite 'existing highway issues - for instance in Knebworth' is a major oversight in the LP and a barrier to resident acceptance of the plan.
The LP acknowledges that it will be necessary to 'work with the Highway Authority when taking forward the development sites set out in the Local Plan. Work on the next iteration of the LTP -the 2050 Transport Vision- is well underway and expected to be finalized by the end of 2016' It is impossible for residents of Knebworth to respond to transport infrastructure issues until the next iteration of the LTP has been released, and I therefore suggest the period of consultation should be extended until after the release of this plan.
Logistic and Location Factors:
The LP references the Statement of Community as reason for easing the 'unmet needs from Luton'. Whilst the developments in North Herts arguably have the space to accommodate this need, it may not be logistically sound. If demand for housing in Luton is high, this suggests people already working in Luton and surrounding areas are driving the demand. With the LP's already acknowledged that 'no rail links from the District to the west exist, meaning towns like Luton and Milton Keynes are less accessible via public transport'. This would put additional strain on road traffic and already strained bus services as those commuting West into Luton and surrounding areas will be forced to commute by car.
GP and Health Services Provision:
Currently the Knebworth Medical Practice has 33 patients per square meter with absolutely no spare capacity for additional patients. This contrasts with the relatively lower patients per square meter in Hitchin and parts of Letchworth. Considering best practice principles suggest that 'the number of registered patients at that practice should not exceed a density of 20 patients per square metre' there is clear evidence that the Knebworth Medical Practice cannot be expected to cope with additional patients. The LP presents that 'an application has recently been submitted for a new library, doctors surgery and pharmacy on the site of the current library' but makes no further mention of this. I suggest that the LP should make provision for these facilities to be approved prior to the plan being accepted, as should the application for these facilities be declined; the village would not be able to cope with the new developments of the LP.
Waste Water:
In the NHDC Infrastructure Delivery Plan, Thames Water's evaluation of sewerage capacity for Knebworth suggests 'Further consideration of sewerage capacity needed and issues with the foul sewer system needs reviewing as the village does not have a dedicated surface water system.'