Local Plan 2011-2031 Proposed Submission Draft

Legal Compliant

During the public consultancy between December 2014 and January, KB4 was not included in this document. So the first time, it is going through this process, is now. KB4 is the largest single site and has the most impact, especially being very close to Stevenage.

I have attached a letter from our local MP, backing up this point and brought into question the legality as it contrary to NHDC's declared process which is set out in the Town and Country Planning (Local Planning) Regulations 2012.

Further information below this document

Is the Plan Positively Prepared?

Knebworth village (already the largest village in Hertfordshire) has 4496 residents in ca 2002 dwellings. The Local Plan is proposing a further 663 houses across four sites. From what I have learnt, any other development of more than 500 houses in a single site, would have to have a Strategic Policy drawn up. Whilst none of the individual sites around the outskirts of Knebworth exceeds this number, the aggregate amount of proposed residences is 663, which represents over 31% increase to our village.

Knebworth has to be considered as one site as all of the proposed sites. As all the sites will have a significate impact on the infrastructure, transportation and highway. The B197 is the main access route and passes North-South through Knebworth High Street, which is already severely congested (Numerous delays on a daily basis). All the sites would feed into the B197 and without any Strategic Policy for Knebworth is clear evidence that the Plan has not been positively prepared.

Is the Plan Justified?

Green Belt

The Local Plan requires the release of Green Belt land. One of the crucial reasons for Green Belt is prevent "coalescence." If the proposed local plan is allowed, in particular KB4 there would be almost continuous housing between Knebworth and Stevenage. Green belt is needed to maintain and specially keep the identity of the village for Knebworth.

The neighbouring authority to the immediate North is Stevenage Borough Council who, in their June 2015 Local Plan housing consultation, concluded that the land showing in the NHDC Plan as KB1 and KB4 make: - 'a significant contribution to Green Belt purposes.'

From my understanding the proposed development of KB4 would breach three of the criteria defined in paragraph 80 of the National Planning Policy Framework, namely:

* to check the unrestricted sprawl of large built-up areas;
* to prevent neighbouring towns merging into one another; and
* To assist in safeguarding the countryside from encroachment.

The Local Plan correctly refers to Knebworth as a Category A village, whereas the supporting documentation refers to it as a 'town', which it is not.

The development on Green belt land would run contrary to:
o National Planning Policy; and
o the value the Council has placed on this land in its own Green Belt review, undertaken less than six months ago (July 2016).
What is more concerning is that other areas of the existing Green belt, which are shown as simply making 'a moderate contribution to Green Belt purposes' are NOT being considered for residential development.
From my understanding, one of the test of "soundness" is that the Local Plan should be 'based on effective joint working on cross-border strategic priorities'. There seems to be a large discrepancy between the two authorities on whether this land is appropriate for building.
Previously Developed Land

KB4 is working agricultural land and has never been previously developed. It should, therefore, not be a priority for development.

Value of the land

The land in KB4 is classified as Grade 3, this being 'good to moderate'. From my understanding, it is therefore should be kept as such. It is not the poorest quality of land and, is in constant agricultural use. Surely removing farmland from around the South East will have a huge effect on local produce and the environmental impact.

So to conclude regarding the Green belt - KB4 is

* 'a significant contribution to Green Belt purposes.'
* Currently preventing "coalescence"
* Is classed as "good to moderate" in agricultural terms

Visual Impact
Living in the village we are lucky to enjoy the countryside, large areas of the KB4 is undulating, if the development goes ahead, it would completely change the characteristics of the village. The outlook and views would be dominated with houses.

Alternative Sites
The issues relating to the land to the West of Stevenage (section 4.104 of the Local Plan refers) should be resolved as soon as possible. This land can provide 3100 house and you will be able to ensure that there are services for all to benefit from. Rather than expanding villages that can't cope with the add houses.

Is the Plan Effective?

Infrastructure

Transport:
In the previous consultation in 2014 it was mentioned the railway line poses huge challenges regarding transport / traffic through the village. These challenges have not been addressed in this plan; in fact, the Plan says (13.195) that there are no mitigation requirements regarding transport. In fact, the Highways Agency has raised this issue previously. The two railway bridges at either end of the village are dangerous due to the current volume of traffic, narrow roads, corners and very narrow pavements. An increase in volume of traffic and pedestrians will make this increasingly dangerous. There have already been many near misses. These two routes are used extensively by small children going to and from school, in the morning rush hour. An increase of 31% of this scale can only add to the problems. This matter has not been addressed and surely makes the not effective.
London Road - (B197) is also a known pinch point; it current takes over 35 minutes to reach junction 6 of the A1 in rush hour, which is only 2 miles away. Increased traffic will only exacerbate this). Any issues on the A1M, it is a prime cut through. If the proposed housing were to be put in place. Any closures on the A1M would result in possibility of gridlock. No real back up for emergency vehicles. Which was actually the case a year ago.
Oakfields Road currently has not through exit. The road bends round into Oakfields avenue. Any access point to the proposed housing at KB4 would completely effect pedestrian right of way to the recreation park or the bridal path. Oakfields Road, which is off B197 is not wide enough to cope with the traffic that would result from the new development. The road would also attract commuter parking, which over the last months, has started encroach part of the road during the working week.
During peak times, a number of roads are used to avoid the traffic, in particular: Old Lane, St Martin's Road, Swangleys Lane, Pondcroft and Gun Lane. These are very narrow and built up, it is already very dangerous for pedestrians, and the increase of 31% would only make it worse.
Swangleys Lane is another alternative route to access the B 197. This is a very narrow country lane with no footpath after the JMI School. Parking is already an issue on the road and severely restricts the flow of traffic along the road, particularly at start and end of the school day. The road mouth onto the B 197 is within 20 metres of a pedestrian crossing and there is already congestion at this junction.

Watton Road is a country lane, with no provision for pedestrians or cyclists for much of its length and quite unsuitable for the volume and nature of the traffic. Watton Road would be one possible access route to the B 197 from KB4.

Public Transport

Knebworth is a commuter village the Train station is extremely busy, it is already overcrowded and peak services have seen a 70% increase over the last ten years.

There is very little employment in the village and any new development would attract the commuter. Yet Govia Thameslink are under consultation to reduce the frequency of trains to/from the local station. Regardless of that, due to where the Station is based, the station is very popular and accessible to residents of Stevenage, this then increases car on the road and parking on local roads. The proposed housings would only increase this further you will need to have permit parking as there is in inadequate commuter parking.

Parking
It has been mentioned the removal of parking onside of the road through the High Street. This has clearly not be thought though:-
* Loss of business to the local shops
* Speed of vehicles - even a vehicle travelling at 30 mph can serious injure someone
* Loss of village centre
Although the road is busy during peak times, it reduces the speed naturally therefore making it safer for children to walk to school. During the day, the cars on either side, prevent traffic and Lorries speeding unnecessary through the village. The parking helps our local shops attract customers from a far, if you were to take parking away from one side, it will be the death of Knebworth villages high street, which is needed for all and in particular by many elderly residents.

Health Services

The doctor's surgery in Knebworth is currently located on Station road. They are in the process of looking for new premises. They have applied for planning permission but it would only improve the current service, which currently takes over 3 weeks to get an appointment. Even if this were successful, the new premises would not be adequate to cope with a 31% increase in the population of the village.

Dentist - there are two surgeries, only one which takes NHS patients, but that one has no capacity for new patients.

Drainage issues:
Drainage issues have been raised time and time again. There will be a major capacity issue at Rye Meads Sewage Treatment Works and this has not been addressed. Surface water is already a problem; this will be exacerbated with increased population and households.
Development in neighbouring village
Planned housing development of 150 houses in Woolmer Green, which lies on the B197 to the South of Knebworth, will only increase the levels of traffic flowing through Knebworth High Street and routes to A1M.

Is the Plan Consistent with National Policy?

I have attached a letter from Stephen McPartland. He states that there are significant failings in the way the Local Plan has been prepared. It very much has the feeling of a rush job and a numbers games, rather than a proper housing plan.

Duty to Co-Operate

The sites on Odyssey, north of Knebworth, has been granted planning permission for approx. 70-100 homes. This number of houses should surely be taken out of Knebworth's allocation and not just taken as a windfall.
As mentioned previously, Stevenage - West, has already been reserved for 3,100 homes. This would be a far better position to provide facilities and services, as the current plan for Knebworth has no support for current and new residents. As I understand that this is on hold is due to secondary school allocation. If a secondary school was built on that site, this would surely resolve this matter and stop adding on housing to over stretch villages.