Local Plan 2011-2031 Proposed Submission Draft

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Object

Local Plan 2011-2031 Proposed Submission Draft

Knebworth

Representation ID: 1987

Received: 24/11/2016

Respondent: Mr Andy Nation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to Knebworth (general): flooding and drainage, road maintenance, traffic, scale of proposed housing, land allocations motivated by profit for landowners, lack of infrastructure, contrary to 2006 study, heritage impact, contrary to strategic objectives, relief road required

Full text:

I have been reading the content of your Local Pan for North Herts and can only wonder where your qualified planners were at the time of it's preparation as they seem to have forgotten the very basics of planning.

As I see it, having been a member of the Chartered Management Institute, the process should go something like;
1. Establish where you are now
2. Establish a need, both now and for the foreseeable future
3. Consider the people involved
4. Put in place a viable plan of action that will take you from where you are now to where you need to be, taking into account;
a. Immediate capital projects needed to provide the infrastructure that will facilitate the main aim
b. Materials and funding to complete the project
c. Changes that may become apparent during the course of the project
d. Agreement from all parties involved in implementation

1. Congratulations! It seems you have completed point 1 successfully - up to a point. There are two main problems with the current situation that you have failed to mention;
a. The NHDC and Highways Departments are currently failing to provide adequate flood protection and drainage to the extent that some roads and junctions are dangerous to pedestrians and motorists whenever there is more than just a light rain. Complaints to the Parish Council, our Member of Parliament, Highways and NHDC have received nil response (copies of correspondence can be provided).
b. The lack on maintenance to the back roads of our village has resulted in erosion to embankments and subsequent deterioration the hard metal of the road surfaces at the edges, not to mention the general deterioration of road surfaces across the village, and indeed, across the county.
c. If this current lack of maintenance is due to lack of funding, how can you possibly expect to maintain an even larger housing stock with the subsequent increase in traffic movements?
Overall then, on point 1, it seems you have failed!

2. There were 2002 existing dwellings in Knebworth in 2011. Now you state the need to add a further 663 up to year 2030. That is a 33% increase - or nearly 10 times the 3% actual increase over the last 5 years (65 homes - completions and permissions). Bearing in mind we are only talking of a planning period up to 2030, unless there are factors you are not telling us about, we should only be looking at about 9% increase - 180 houses. Bearing in mind we will soon be exiting the European Union and the Government are committed to securing our borders which should slow down immigration, we may actually see a lesser need over the period. To justify your stated need for 663 new homes the local population would need to breed like rabbits! So on point 2, you have also failed.

3. Let us assume for a moment that most people are not fools. They will, without reservation accept that some development to provide sustainable growth will be required in their village. They will not, however, accept figures and plans thrust upon them without a logical explanation of how they were derived. The fact that some land owners see £ signs in front of their eyes when you ask if they are happy to give up their land for building is not justification for proposing to actually build on all those plots. So once again, on point 3, you have failed.

4. The people (residents) are bound to be concerned when they see proposals that are not backed up by sound planning. Apart from the proposal to provide relatively inadequate additional primary schooling and a possible secondary school (no details) your plans lack any infrastructure details to provide the necessary roads, drainage (both surface and foul - There is a major capacity issue at Rye Meads Sewage treatment Works), local employment opportunity or additional retail facilities. Indeed, you plan to reduce the retail facilities by putting housing on the Chas Lowe site.
At a previous Parish Council meeting The NHDC representative said that no infrastructure details had been included with your Local Plan as "it would be up to the individual house builders to submit proposals for roads, flood mitigation and drainage in their individual planning applications". This is a total abrogation of the Council's responsibility and the villagers will not stand for such a slap-dash attitude towards such a major proposed development. Again, NHDC, your Local Plan has failed.

Now let us consider some of the details, particularly on the west side of Knebworth, that proves your Local Plan is ill-conceived;

Irrespective of your Council's proposed destruction of the greenbelt, you would also be acting against your own 2006 study which stated that "Knebworth is not suitable for further development as it would risk the sustainability of the village". Nothing has changed since then so it seems you make sound-bites to suit yourselves!

There are two Conservation Areas adjacent to the proposed development areas; Stockens Green & Deards End Lane, which NHDC is responsible for maintaining. Allowing dense house building so close to these areas would go against NHDC's own publicly stated policy regarding the sites' importance, which includes a section of Park Lane. Furthermore Core Strategy EN2 Covering Protection and Enhancement of Landscape and Settlement Character states that development proposals should demonstrate that their location, scale, design, and materials will protect, conserve and, where possible enhance: The setting of, and views from Conservation areas. Therefore building a high density housing estate next to these conservation areas would contravene Core Strategy EN2 by ruining their setting and views. The Strategic objectives ENV1, ENV2, ENV3 and ENV5 will also be contravened by such a huge scheme in relation to the present size of Knebworth.

Access to these two sites, has to be via one of 4 narrow railway bridges, 3 of which have limited vision, which are pinch points and already cause congestion and accidents. Unless the railway bridges are widened the congestion will get worse. However, widening these bridges and straightening the approaches is not a viable option, especially the one at Deards End Lane. The best of the 4 bridges is the one at Woolmer Green but the road to the west of it is a single track along Wych Elm Lane between open fields

Deards End Lane and Gypsy Lane are already too heavily used by traffic between Stevenage & A1(M), and Codicote, Whitwell, Wheathampstead, Harpenden, Luton and Welwyn. These roads are too narrow to accommodate two way traffic along much of their length. Already, erosion to the verges, drive entrances and the edge of the carriageway testify to this with many potholes. Many of the entrances to these properties are blind making it difficult for residents to exit as well for cars using the road. The resulting increase in traffic on these roads would not only lead to further deterioration of these lanes, and the fact they lack any pedestrian pathways would undoubtedly lead to increased pedestrian accidents. This danger to pedestrians through lack of pathways and flooding is a constant concern as vehicles have been monitored along Deards End Lane at over 40 miles per hour. Pedestrian accidents have been reported to the Police and the Council but requests to introduce a 20 miles per hour speed limit have either been flatly refused "until someone is killed", or been pushed from pillar to post - each department denying it is their job.

Widening these roads, particularly Deard's End Lane, would totally destroy the character of this conservation area and would be totally unacceptable. The proposed developments would require new access points to be arranged off the B197 and the A1(M) B197 south and north of Knebworth to provide a bypass for Knebworth and for access to the developments west of Deards End Lane and Gypsy Lane. This would be essential before any development could possibly begin.

You have mentioned in your plan regarding Knebworth "the High Street is a known pinch point, particularly when delays or incidents on the A1(M) result in the B197 being used as
an alternate route between Welwyn Garden City and Stevenage." With just a modicum of joined up thinking for the future, this problem can be partially relieved by bypassing Knebworth with a relief road. I would propose you consider the following;

The bridge at Bridge Rod, Woolmer Green is the only bridge offering reasonable access to the west of Knebworth. So;
1. Put a roundabout at the junction B197/Bridge Road
2. Improve the road Wych Elm Lane by widening and straightening slightly up to Gypsy Lane
3. From where Gypsy Lane veers away from being next to, and parallel to, the A1(M) motorway, make a new road continuing parallel to the motorway, through your proposed Gypsy Lane development site, to meet and cross over Park Lane at a mini roundabout.
4. Continue the new road parallel to the motorway, through your proposed development site to the west of Deards End Lane Conservation Area, continuing along the very west fringe of Knebworth Golf Course (which would not interfere with their fairways), to cross over Old Knebworth Lane at a mini roundabout.
5. Continue the new road parallel to the motorway, through the west side of the proposed Science Park to meet the A602.

This proposal would address a whole host of problems;
* Pinch point at Knebworth High Street
* Access to the west side of Knebworth
* Relief road in the event of A1(M) closure between Stevenage south and Welwyn
* Congestion at peak times for traffic accessing the B197 from the A602
* Now that QEII Hospital A&E has been closed, emergency ambulances would have a shorter time to reach Lister Hospital in the event of traffic congestion
* Traffic from Welwyn west, Whitwell and Codicote and all points west would have easier access to Stevenage and beyond
Failure to adopt this proposal would be a major reason for your proposed development west of Knebworth to fail. Proposals 1 - 4 above would be the minimum to justify ANY development west of Knebworth.

I continue to give details below, not just about your justification, or lack of, for the density of your proposed housing but also the need for such housing.
Some of the low lying houses in Orchard Way and Broom Grove are already subject to flooding after heavy rain from excess run off from the fields to the west. Flooding is also a problem in
the High Street and Pondcroft Road where sandbags have to be used to block doorways during heavy rain. Some of the existing drains are blocked by stones and gravel. Covering those fields (052) with concrete would only make matters worse. No details are given of what type of sustainable drainage systems would be needed for preventing flooding of parts of Knebworth are included. It would certainly have to be a large system such as a flood run-off storage reservoir near the middle of the new development where the ground slopes down, to control the flooding of parts of Knebworth including Orchard Way and Broom Grove. Flooding occurs at the junction of Deards End Lane with Park Lane EVERY time it rains as the controlling body does not have the funds or the inclination to do anything about it (see attached pictures) and this has been the case for many years. The surface drain at that point is currently 4 inches deep in sludge over the top of the drain hole and plants are now growing there. What hope is there for effective major flood defences elsewhere in the village, particularly if developers are going to asked to pay for it?

The additional infrastructure and alterations needed to cope with your proposed 33% increase in the resident population would have to include; extra car parks, expansion of Knebworth Station car park and ticket office staff and opening times, a new school, library, a new larger village hall, a new bigger doctors' surgery with adequate free parking outside. Building houses on the Chas Lowe site is really inappropriate as this is the most appropriate location for a new doctor's surgery, and new library rather than the restrictive site currently proposed in St Martin's Lane. Very short sighted! The Chase Lowe site should also be fronted by retails units to maintain the sustainability of the village centre.

At present the plan contravenes Strategic objective ECON8 which requires all development to be supported by the necessary provision of improvements to infrastructure, services and facilities. It also contravenes SOC4 which enables rural communities to plan to meet their own local needs, especially through neighbourhood planning.

Many of the objections outlined above have been made to you by many people since early 2015 yet you appear to have ignored them. It is crystal clear that the proposed developments contravene many of your strategic objectives, as well as being out of all proportion to the size of the village and will create major congestion problems. You have also failed to explain how you have calculated the number of new houses needed in this area.

To conform to SOC4 you need to be able to answer the concerns and objections you have received and provide detailed answers to accord with the provisions of ECON 8. Whilst you believe the developers will sort out all these issues raised, you need to be able to justify the housing need, answer concerns of residents over infrastructure etc or go back to the drawing board.

For the above reasons your proposed developments should not go ahead as they are presently drafted.

Object

Local Plan 2011-2031 Proposed Submission Draft

Policy SP8: Housing

Representation ID: 5759

Received: 24/11/2016

Respondent: Mr Andy Nation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to SP8: Housing numbers not justified, impact of Brexit

Full text:

I have been reading the content of your Local Pan for North Herts and can only wonder where your qualified planners were at the time of it's preparation as they seem to have forgotten the very basics of planning.

As I see it, having been a member of the Chartered Management Institute, the process should go something like;
1. Establish where you are now
2. Establish a need, both now and for the foreseeable future
3. Consider the people involved
4. Put in place a viable plan of action that will take you from where you are now to where you need to be, taking into account;
a. Immediate capital projects needed to provide the infrastructure that will facilitate the main aim
b. Materials and funding to complete the project
c. Changes that may become apparent during the course of the project
d. Agreement from all parties involved in implementation

1. Congratulations! It seems you have completed point 1 successfully - up to a point. There are two main problems with the current situation that you have failed to mention;
a. The NHDC and Highways Departments are currently failing to provide adequate flood protection and drainage to the extent that some roads and junctions are dangerous to pedestrians and motorists whenever there is more than just a light rain. Complaints to the Parish Council, our Member of Parliament, Highways and NHDC have received nil response (copies of correspondence can be provided).
b. The lack on maintenance to the back roads of our village has resulted in erosion to embankments and subsequent deterioration the hard metal of the road surfaces at the edges, not to mention the general deterioration of road surfaces across the village, and indeed, across the county.
c. If this current lack of maintenance is due to lack of funding, how can you possibly expect to maintain an even larger housing stock with the subsequent increase in traffic movements?
Overall then, on point 1, it seems you have failed!

2. There were 2002 existing dwellings in Knebworth in 2011. Now you state the need to add a further 663 up to year 2030. That is a 33% increase - or nearly 10 times the 3% actual increase over the last 5 years (65 homes - completions and permissions). Bearing in mind we are only talking of a planning period up to 2030, unless there are factors you are not telling us about, we should only be looking at about 9% increase - 180 houses. Bearing in mind we will soon be exiting the European Union and the Government are committed to securing our borders which should slow down immigration, we may actually see a lesser need over the period. To justify your stated need for 663 new homes the local population would need to breed like rabbits! So on point 2, you have also failed.

3. Let us assume for a moment that most people are not fools. They will, without reservation accept that some development to provide sustainable growth will be required in their village. They will not, however, accept figures and plans thrust upon them without a logical explanation of how they were derived. The fact that some land owners see £ signs in front of their eyes when you ask if they are happy to give up their land for building is not justification for proposing to actually build on all those plots. So once again, on point 3, you have failed.

4. The people (residents) are bound to be concerned when they see proposals that are not backed up by sound planning. Apart from the proposal to provide relatively inadequate additional primary schooling and a possible secondary school (no details) your plans lack any infrastructure details to provide the necessary roads, drainage (both surface and foul - There is a major capacity issue at Rye Meads Sewage treatment Works), local employment opportunity or additional retail facilities. Indeed, you plan to reduce the retail facilities by putting housing on the Chas Lowe site.
At a previous Parish Council meeting The NHDC representative said that no infrastructure details had been included with your Local Plan as "it would be up to the individual house builders to submit proposals for roads, flood mitigation and drainage in their individual planning applications". This is a total abrogation of the Council's responsibility and the villagers will not stand for such a slap-dash attitude towards such a major proposed development. Again, NHDC, your Local Plan has failed.

Now let us consider some of the details, particularly on the west side of Knebworth, that proves your Local Plan is ill-conceived;

Irrespective of your Council's proposed destruction of the greenbelt, you would also be acting against your own 2006 study which stated that "Knebworth is not suitable for further development as it would risk the sustainability of the village". Nothing has changed since then so it seems you make sound-bites to suit yourselves!

There are two Conservation Areas adjacent to the proposed development areas; Stockens Green & Deards End Lane, which NHDC is responsible for maintaining. Allowing dense house building so close to these areas would go against NHDC's own publicly stated policy regarding the sites' importance, which includes a section of Park Lane. Furthermore Core Strategy EN2 Covering Protection and Enhancement of Landscape and Settlement Character states that development proposals should demonstrate that their location, scale, design, and materials will protect, conserve and, where possible enhance: The setting of, and views from Conservation areas. Therefore building a high density housing estate next to these conservation areas would contravene Core Strategy EN2 by ruining their setting and views. The Strategic objectives ENV1, ENV2, ENV3 and ENV5 will also be contravened by such a huge scheme in relation to the present size of Knebworth.

Access to these two sites, has to be via one of 4 narrow railway bridges, 3 of which have limited vision, which are pinch points and already cause congestion and accidents. Unless the railway bridges are widened the congestion will get worse. However, widening these bridges and straightening the approaches is not a viable option, especially the one at Deards End Lane. The best of the 4 bridges is the one at Woolmer Green but the road to the west of it is a single track along Wych Elm Lane between open fields

Deards End Lane and Gypsy Lane are already too heavily used by traffic between Stevenage & A1(M), and Codicote, Whitwell, Wheathampstead, Harpenden, Luton and Welwyn. These roads are too narrow to accommodate two way traffic along much of their length. Already, erosion to the verges, drive entrances and the edge of the carriageway testify to this with many potholes. Many of the entrances to these properties are blind making it difficult for residents to exit as well for cars using the road. The resulting increase in traffic on these roads would not only lead to further deterioration of these lanes, and the fact they lack any pedestrian pathways would undoubtedly lead to increased pedestrian accidents. This danger to pedestrians through lack of pathways and flooding is a constant concern as vehicles have been monitored along Deards End Lane at over 40 miles per hour. Pedestrian accidents have been reported to the Police and the Council but requests to introduce a 20 miles per hour speed limit have either been flatly refused "until someone is killed", or been pushed from pillar to post - each department denying it is their job.

Widening these roads, particularly Deard's End Lane, would totally destroy the character of this conservation area and would be totally unacceptable. The proposed developments would require new access points to be arranged off the B197 and the A1(M) B197 south and north of Knebworth to provide a bypass for Knebworth and for access to the developments west of Deards End Lane and Gypsy Lane. This would be essential before any development could possibly begin.

You have mentioned in your plan regarding Knebworth "the High Street is a known pinch point, particularly when delays or incidents on the A1(M) result in the B197 being used as
an alternate route between Welwyn Garden City and Stevenage." With just a modicum of joined up thinking for the future, this problem can be partially relieved by bypassing Knebworth with a relief road. I would propose you consider the following;

The bridge at Bridge Rod, Woolmer Green is the only bridge offering reasonable access to the west of Knebworth. So;
1. Put a roundabout at the junction B197/Bridge Road
2. Improve the road Wych Elm Lane by widening and straightening slightly up to Gypsy Lane
3. From where Gypsy Lane veers away from being next to, and parallel to, the A1(M) motorway, make a new road continuing parallel to the motorway, through your proposed Gypsy Lane development site, to meet and cross over Park Lane at a mini roundabout.
4. Continue the new road parallel to the motorway, through your proposed development site to the west of Deards End Lane Conservation Area, continuing along the very west fringe of Knebworth Golf Course (which would not interfere with their fairways), to cross over Old Knebworth Lane at a mini roundabout.
5. Continue the new road parallel to the motorway, through the west side of the proposed Science Park to meet the A602.

This proposal would address a whole host of problems;
* Pinch point at Knebworth High Street
* Access to the west side of Knebworth
* Relief road in the event of A1(M) closure between Stevenage south and Welwyn
* Congestion at peak times for traffic accessing the B197 from the A602
* Now that QEII Hospital A&E has been closed, emergency ambulances would have a shorter time to reach Lister Hospital in the event of traffic congestion
* Traffic from Welwyn west, Whitwell and Codicote and all points west would have easier access to Stevenage and beyond
Failure to adopt this proposal would be a major reason for your proposed development west of Knebworth to fail. Proposals 1 - 4 above would be the minimum to justify ANY development west of Knebworth.

I continue to give details below, not just about your justification, or lack of, for the density of your proposed housing but also the need for such housing.
Some of the low lying houses in Orchard Way and Broom Grove are already subject to flooding after heavy rain from excess run off from the fields to the west. Flooding is also a problem in
the High Street and Pondcroft Road where sandbags have to be used to block doorways during heavy rain. Some of the existing drains are blocked by stones and gravel. Covering those fields (052) with concrete would only make matters worse. No details are given of what type of sustainable drainage systems would be needed for preventing flooding of parts of Knebworth are included. It would certainly have to be a large system such as a flood run-off storage reservoir near the middle of the new development where the ground slopes down, to control the flooding of parts of Knebworth including Orchard Way and Broom Grove. Flooding occurs at the junction of Deards End Lane with Park Lane EVERY time it rains as the controlling body does not have the funds or the inclination to do anything about it (see attached pictures) and this has been the case for many years. The surface drain at that point is currently 4 inches deep in sludge over the top of the drain hole and plants are now growing there. What hope is there for effective major flood defences elsewhere in the village, particularly if developers are going to asked to pay for it?

The additional infrastructure and alterations needed to cope with your proposed 33% increase in the resident population would have to include; extra car parks, expansion of Knebworth Station car park and ticket office staff and opening times, a new school, library, a new larger village hall, a new bigger doctors' surgery with adequate free parking outside. Building houses on the Chas Lowe site is really inappropriate as this is the most appropriate location for a new doctor's surgery, and new library rather than the restrictive site currently proposed in St Martin's Lane. Very short sighted! The Chase Lowe site should also be fronted by retails units to maintain the sustainability of the village centre.

At present the plan contravenes Strategic objective ECON8 which requires all development to be supported by the necessary provision of improvements to infrastructure, services and facilities. It also contravenes SOC4 which enables rural communities to plan to meet their own local needs, especially through neighbourhood planning.

Many of the objections outlined above have been made to you by many people since early 2015 yet you appear to have ignored them. It is crystal clear that the proposed developments contravene many of your strategic objectives, as well as being out of all proportion to the size of the village and will create major congestion problems. You have also failed to explain how you have calculated the number of new houses needed in this area.

To conform to SOC4 you need to be able to answer the concerns and objections you have received and provide detailed answers to accord with the provisions of ECON 8. Whilst you believe the developers will sort out all these issues raised, you need to be able to justify the housing need, answer concerns of residents over infrastructure etc or go back to the drawing board.

For the above reasons your proposed developments should not go ahead as they are presently drafted.

Object

Local Plan 2011-2031 Proposed Submission Draft

KB1 Land at Deards End

Representation ID: 5760

Received: 24/11/2016

Respondent: Mr Andy Nation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to KB1: Traffic, flooding, heritage impact, inadequate access, highway safety, Green Belt, lack of detail on SUDs

Full text:

I have been reading the content of your Local Pan for North Herts and can only wonder where your qualified planners were at the time of it's preparation as they seem to have forgotten the very basics of planning.

As I see it, having been a member of the Chartered Management Institute, the process should go something like;
1. Establish where you are now
2. Establish a need, both now and for the foreseeable future
3. Consider the people involved
4. Put in place a viable plan of action that will take you from where you are now to where you need to be, taking into account;
a. Immediate capital projects needed to provide the infrastructure that will facilitate the main aim
b. Materials and funding to complete the project
c. Changes that may become apparent during the course of the project
d. Agreement from all parties involved in implementation

1. Congratulations! It seems you have completed point 1 successfully - up to a point. There are two main problems with the current situation that you have failed to mention;
a. The NHDC and Highways Departments are currently failing to provide adequate flood protection and drainage to the extent that some roads and junctions are dangerous to pedestrians and motorists whenever there is more than just a light rain. Complaints to the Parish Council, our Member of Parliament, Highways and NHDC have received nil response (copies of correspondence can be provided).
b. The lack on maintenance to the back roads of our village has resulted in erosion to embankments and subsequent deterioration the hard metal of the road surfaces at the edges, not to mention the general deterioration of road surfaces across the village, and indeed, across the county.
c. If this current lack of maintenance is due to lack of funding, how can you possibly expect to maintain an even larger housing stock with the subsequent increase in traffic movements?
Overall then, on point 1, it seems you have failed!

2. There were 2002 existing dwellings in Knebworth in 2011. Now you state the need to add a further 663 up to year 2030. That is a 33% increase - or nearly 10 times the 3% actual increase over the last 5 years (65 homes - completions and permissions). Bearing in mind we are only talking of a planning period up to 2030, unless there are factors you are not telling us about, we should only be looking at about 9% increase - 180 houses. Bearing in mind we will soon be exiting the European Union and the Government are committed to securing our borders which should slow down immigration, we may actually see a lesser need over the period. To justify your stated need for 663 new homes the local population would need to breed like rabbits! So on point 2, you have also failed.

3. Let us assume for a moment that most people are not fools. They will, without reservation accept that some development to provide sustainable growth will be required in their village. They will not, however, accept figures and plans thrust upon them without a logical explanation of how they were derived. The fact that some land owners see £ signs in front of their eyes when you ask if they are happy to give up their land for building is not justification for proposing to actually build on all those plots. So once again, on point 3, you have failed.

4. The people (residents) are bound to be concerned when they see proposals that are not backed up by sound planning. Apart from the proposal to provide relatively inadequate additional primary schooling and a possible secondary school (no details) your plans lack any infrastructure details to provide the necessary roads, drainage (both surface and foul - There is a major capacity issue at Rye Meads Sewage treatment Works), local employment opportunity or additional retail facilities. Indeed, you plan to reduce the retail facilities by putting housing on the Chas Lowe site.
At a previous Parish Council meeting The NHDC representative said that no infrastructure details had been included with your Local Plan as "it would be up to the individual house builders to submit proposals for roads, flood mitigation and drainage in their individual planning applications". This is a total abrogation of the Council's responsibility and the villagers will not stand for such a slap-dash attitude towards such a major proposed development. Again, NHDC, your Local Plan has failed.

Now let us consider some of the details, particularly on the west side of Knebworth, that proves your Local Plan is ill-conceived;

Irrespective of your Council's proposed destruction of the greenbelt, you would also be acting against your own 2006 study which stated that "Knebworth is not suitable for further development as it would risk the sustainability of the village". Nothing has changed since then so it seems you make sound-bites to suit yourselves!

There are two Conservation Areas adjacent to the proposed development areas; Stockens Green & Deards End Lane, which NHDC is responsible for maintaining. Allowing dense house building so close to these areas would go against NHDC's own publicly stated policy regarding the sites' importance, which includes a section of Park Lane. Furthermore Core Strategy EN2 Covering Protection and Enhancement of Landscape and Settlement Character states that development proposals should demonstrate that their location, scale, design, and materials will protect, conserve and, where possible enhance: The setting of, and views from Conservation areas. Therefore building a high density housing estate next to these conservation areas would contravene Core Strategy EN2 by ruining their setting and views. The Strategic objectives ENV1, ENV2, ENV3 and ENV5 will also be contravened by such a huge scheme in relation to the present size of Knebworth.

Access to these two sites, has to be via one of 4 narrow railway bridges, 3 of which have limited vision, which are pinch points and already cause congestion and accidents. Unless the railway bridges are widened the congestion will get worse. However, widening these bridges and straightening the approaches is not a viable option, especially the one at Deards End Lane. The best of the 4 bridges is the one at Woolmer Green but the road to the west of it is a single track along Wych Elm Lane between open fields

Deards End Lane and Gypsy Lane are already too heavily used by traffic between Stevenage & A1(M), and Codicote, Whitwell, Wheathampstead, Harpenden, Luton and Welwyn. These roads are too narrow to accommodate two way traffic along much of their length. Already, erosion to the verges, drive entrances and the edge of the carriageway testify to this with many potholes. Many of the entrances to these properties are blind making it difficult for residents to exit as well for cars using the road. The resulting increase in traffic on these roads would not only lead to further deterioration of these lanes, and the fact they lack any pedestrian pathways would undoubtedly lead to increased pedestrian accidents. This danger to pedestrians through lack of pathways and flooding is a constant concern as vehicles have been monitored along Deards End Lane at over 40 miles per hour. Pedestrian accidents have been reported to the Police and the Council but requests to introduce a 20 miles per hour speed limit have either been flatly refused "until someone is killed", or been pushed from pillar to post - each department denying it is their job.

Widening these roads, particularly Deard's End Lane, would totally destroy the character of this conservation area and would be totally unacceptable. The proposed developments would require new access points to be arranged off the B197 and the A1(M) B197 south and north of Knebworth to provide a bypass for Knebworth and for access to the developments west of Deards End Lane and Gypsy Lane. This would be essential before any development could possibly begin.

You have mentioned in your plan regarding Knebworth "the High Street is a known pinch point, particularly when delays or incidents on the A1(M) result in the B197 being used as
an alternate route between Welwyn Garden City and Stevenage." With just a modicum of joined up thinking for the future, this problem can be partially relieved by bypassing Knebworth with a relief road. I would propose you consider the following;

The bridge at Bridge Rod, Woolmer Green is the only bridge offering reasonable access to the west of Knebworth. So;
1. Put a roundabout at the junction B197/Bridge Road
2. Improve the road Wych Elm Lane by widening and straightening slightly up to Gypsy Lane
3. From where Gypsy Lane veers away from being next to, and parallel to, the A1(M) motorway, make a new road continuing parallel to the motorway, through your proposed Gypsy Lane development site, to meet and cross over Park Lane at a mini roundabout.
4. Continue the new road parallel to the motorway, through your proposed development site to the west of Deards End Lane Conservation Area, continuing along the very west fringe of Knebworth Golf Course (which would not interfere with their fairways), to cross over Old Knebworth Lane at a mini roundabout.
5. Continue the new road parallel to the motorway, through the west side of the proposed Science Park to meet the A602.

This proposal would address a whole host of problems;
* Pinch point at Knebworth High Street
* Access to the west side of Knebworth
* Relief road in the event of A1(M) closure between Stevenage south and Welwyn
* Congestion at peak times for traffic accessing the B197 from the A602
* Now that QEII Hospital A&E has been closed, emergency ambulances would have a shorter time to reach Lister Hospital in the event of traffic congestion
* Traffic from Welwyn west, Whitwell and Codicote and all points west would have easier access to Stevenage and beyond
Failure to adopt this proposal would be a major reason for your proposed development west of Knebworth to fail. Proposals 1 - 4 above would be the minimum to justify ANY development west of Knebworth.

I continue to give details below, not just about your justification, or lack of, for the density of your proposed housing but also the need for such housing.
Some of the low lying houses in Orchard Way and Broom Grove are already subject to flooding after heavy rain from excess run off from the fields to the west. Flooding is also a problem in
the High Street and Pondcroft Road where sandbags have to be used to block doorways during heavy rain. Some of the existing drains are blocked by stones and gravel. Covering those fields (052) with concrete would only make matters worse. No details are given of what type of sustainable drainage systems would be needed for preventing flooding of parts of Knebworth are included. It would certainly have to be a large system such as a flood run-off storage reservoir near the middle of the new development where the ground slopes down, to control the flooding of parts of Knebworth including Orchard Way and Broom Grove. Flooding occurs at the junction of Deards End Lane with Park Lane EVERY time it rains as the controlling body does not have the funds or the inclination to do anything about it (see attached pictures) and this has been the case for many years. The surface drain at that point is currently 4 inches deep in sludge over the top of the drain hole and plants are now growing there. What hope is there for effective major flood defences elsewhere in the village, particularly if developers are going to asked to pay for it?

The additional infrastructure and alterations needed to cope with your proposed 33% increase in the resident population would have to include; extra car parks, expansion of Knebworth Station car park and ticket office staff and opening times, a new school, library, a new larger village hall, a new bigger doctors' surgery with adequate free parking outside. Building houses on the Chas Lowe site is really inappropriate as this is the most appropriate location for a new doctor's surgery, and new library rather than the restrictive site currently proposed in St Martin's Lane. Very short sighted! The Chase Lowe site should also be fronted by retails units to maintain the sustainability of the village centre.

At present the plan contravenes Strategic objective ECON8 which requires all development to be supported by the necessary provision of improvements to infrastructure, services and facilities. It also contravenes SOC4 which enables rural communities to plan to meet their own local needs, especially through neighbourhood planning.

Many of the objections outlined above have been made to you by many people since early 2015 yet you appear to have ignored them. It is crystal clear that the proposed developments contravene many of your strategic objectives, as well as being out of all proportion to the size of the village and will create major congestion problems. You have also failed to explain how you have calculated the number of new houses needed in this area.

To conform to SOC4 you need to be able to answer the concerns and objections you have received and provide detailed answers to accord with the provisions of ECON 8. Whilst you believe the developers will sort out all these issues raised, you need to be able to justify the housing need, answer concerns of residents over infrastructure etc or go back to the drawing board.

For the above reasons your proposed developments should not go ahead as they are presently drafted.

Object

Local Plan 2011-2031 Proposed Submission Draft

KB2 Land off Gypsy Lane

Representation ID: 5761

Received: 24/11/2016

Respondent: Mr Andy Nation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to KB2: Traffic, flooding, heritage impact, inadequate access, highway safety, Green Belt, lack of detail on SUDs

Full text:

I have been reading the content of your Local Pan for North Herts and can only wonder where your qualified planners were at the time of it's preparation as they seem to have forgotten the very basics of planning.

As I see it, having been a member of the Chartered Management Institute, the process should go something like;
1. Establish where you are now
2. Establish a need, both now and for the foreseeable future
3. Consider the people involved
4. Put in place a viable plan of action that will take you from where you are now to where you need to be, taking into account;
a. Immediate capital projects needed to provide the infrastructure that will facilitate the main aim
b. Materials and funding to complete the project
c. Changes that may become apparent during the course of the project
d. Agreement from all parties involved in implementation

1. Congratulations! It seems you have completed point 1 successfully - up to a point. There are two main problems with the current situation that you have failed to mention;
a. The NHDC and Highways Departments are currently failing to provide adequate flood protection and drainage to the extent that some roads and junctions are dangerous to pedestrians and motorists whenever there is more than just a light rain. Complaints to the Parish Council, our Member of Parliament, Highways and NHDC have received nil response (copies of correspondence can be provided).
b. The lack on maintenance to the back roads of our village has resulted in erosion to embankments and subsequent deterioration the hard metal of the road surfaces at the edges, not to mention the general deterioration of road surfaces across the village, and indeed, across the county.
c. If this current lack of maintenance is due to lack of funding, how can you possibly expect to maintain an even larger housing stock with the subsequent increase in traffic movements?
Overall then, on point 1, it seems you have failed!

2. There were 2002 existing dwellings in Knebworth in 2011. Now you state the need to add a further 663 up to year 2030. That is a 33% increase - or nearly 10 times the 3% actual increase over the last 5 years (65 homes - completions and permissions). Bearing in mind we are only talking of a planning period up to 2030, unless there are factors you are not telling us about, we should only be looking at about 9% increase - 180 houses. Bearing in mind we will soon be exiting the European Union and the Government are committed to securing our borders which should slow down immigration, we may actually see a lesser need over the period. To justify your stated need for 663 new homes the local population would need to breed like rabbits! So on point 2, you have also failed.

3. Let us assume for a moment that most people are not fools. They will, without reservation accept that some development to provide sustainable growth will be required in their village. They will not, however, accept figures and plans thrust upon them without a logical explanation of how they were derived. The fact that some land owners see £ signs in front of their eyes when you ask if they are happy to give up their land for building is not justification for proposing to actually build on all those plots. So once again, on point 3, you have failed.

4. The people (residents) are bound to be concerned when they see proposals that are not backed up by sound planning. Apart from the proposal to provide relatively inadequate additional primary schooling and a possible secondary school (no details) your plans lack any infrastructure details to provide the necessary roads, drainage (both surface and foul - There is a major capacity issue at Rye Meads Sewage treatment Works), local employment opportunity or additional retail facilities. Indeed, you plan to reduce the retail facilities by putting housing on the Chas Lowe site.
At a previous Parish Council meeting The NHDC representative said that no infrastructure details had been included with your Local Plan as "it would be up to the individual house builders to submit proposals for roads, flood mitigation and drainage in their individual planning applications". This is a total abrogation of the Council's responsibility and the villagers will not stand for such a slap-dash attitude towards such a major proposed development. Again, NHDC, your Local Plan has failed.

Now let us consider some of the details, particularly on the west side of Knebworth, that proves your Local Plan is ill-conceived;

Irrespective of your Council's proposed destruction of the greenbelt, you would also be acting against your own 2006 study which stated that "Knebworth is not suitable for further development as it would risk the sustainability of the village". Nothing has changed since then so it seems you make sound-bites to suit yourselves!

There are two Conservation Areas adjacent to the proposed development areas; Stockens Green & Deards End Lane, which NHDC is responsible for maintaining. Allowing dense house building so close to these areas would go against NHDC's own publicly stated policy regarding the sites' importance, which includes a section of Park Lane. Furthermore Core Strategy EN2 Covering Protection and Enhancement of Landscape and Settlement Character states that development proposals should demonstrate that their location, scale, design, and materials will protect, conserve and, where possible enhance: The setting of, and views from Conservation areas. Therefore building a high density housing estate next to these conservation areas would contravene Core Strategy EN2 by ruining their setting and views. The Strategic objectives ENV1, ENV2, ENV3 and ENV5 will also be contravened by such a huge scheme in relation to the present size of Knebworth.

Access to these two sites, has to be via one of 4 narrow railway bridges, 3 of which have limited vision, which are pinch points and already cause congestion and accidents. Unless the railway bridges are widened the congestion will get worse. However, widening these bridges and straightening the approaches is not a viable option, especially the one at Deards End Lane. The best of the 4 bridges is the one at Woolmer Green but the road to the west of it is a single track along Wych Elm Lane between open fields

Deards End Lane and Gypsy Lane are already too heavily used by traffic between Stevenage & A1(M), and Codicote, Whitwell, Wheathampstead, Harpenden, Luton and Welwyn. These roads are too narrow to accommodate two way traffic along much of their length. Already, erosion to the verges, drive entrances and the edge of the carriageway testify to this with many potholes. Many of the entrances to these properties are blind making it difficult for residents to exit as well for cars using the road. The resulting increase in traffic on these roads would not only lead to further deterioration of these lanes, and the fact they lack any pedestrian pathways would undoubtedly lead to increased pedestrian accidents. This danger to pedestrians through lack of pathways and flooding is a constant concern as vehicles have been monitored along Deards End Lane at over 40 miles per hour. Pedestrian accidents have been reported to the Police and the Council but requests to introduce a 20 miles per hour speed limit have either been flatly refused "until someone is killed", or been pushed from pillar to post - each department denying it is their job.

Widening these roads, particularly Deard's End Lane, would totally destroy the character of this conservation area and would be totally unacceptable. The proposed developments would require new access points to be arranged off the B197 and the A1(M) B197 south and north of Knebworth to provide a bypass for Knebworth and for access to the developments west of Deards End Lane and Gypsy Lane. This would be essential before any development could possibly begin.

You have mentioned in your plan regarding Knebworth "the High Street is a known pinch point, particularly when delays or incidents on the A1(M) result in the B197 being used as
an alternate route between Welwyn Garden City and Stevenage." With just a modicum of joined up thinking for the future, this problem can be partially relieved by bypassing Knebworth with a relief road. I would propose you consider the following;

The bridge at Bridge Rod, Woolmer Green is the only bridge offering reasonable access to the west of Knebworth. So;
1. Put a roundabout at the junction B197/Bridge Road
2. Improve the road Wych Elm Lane by widening and straightening slightly up to Gypsy Lane
3. From where Gypsy Lane veers away from being next to, and parallel to, the A1(M) motorway, make a new road continuing parallel to the motorway, through your proposed Gypsy Lane development site, to meet and cross over Park Lane at a mini roundabout.
4. Continue the new road parallel to the motorway, through your proposed development site to the west of Deards End Lane Conservation Area, continuing along the very west fringe of Knebworth Golf Course (which would not interfere with their fairways), to cross over Old Knebworth Lane at a mini roundabout.
5. Continue the new road parallel to the motorway, through the west side of the proposed Science Park to meet the A602.

This proposal would address a whole host of problems;
* Pinch point at Knebworth High Street
* Access to the west side of Knebworth
* Relief road in the event of A1(M) closure between Stevenage south and Welwyn
* Congestion at peak times for traffic accessing the B197 from the A602
* Now that QEII Hospital A&E has been closed, emergency ambulances would have a shorter time to reach Lister Hospital in the event of traffic congestion
* Traffic from Welwyn west, Whitwell and Codicote and all points west would have easier access to Stevenage and beyond
Failure to adopt this proposal would be a major reason for your proposed development west of Knebworth to fail. Proposals 1 - 4 above would be the minimum to justify ANY development west of Knebworth.

I continue to give details below, not just about your justification, or lack of, for the density of your proposed housing but also the need for such housing.
Some of the low lying houses in Orchard Way and Broom Grove are already subject to flooding after heavy rain from excess run off from the fields to the west. Flooding is also a problem in
the High Street and Pondcroft Road where sandbags have to be used to block doorways during heavy rain. Some of the existing drains are blocked by stones and gravel. Covering those fields (052) with concrete would only make matters worse. No details are given of what type of sustainable drainage systems would be needed for preventing flooding of parts of Knebworth are included. It would certainly have to be a large system such as a flood run-off storage reservoir near the middle of the new development where the ground slopes down, to control the flooding of parts of Knebworth including Orchard Way and Broom Grove. Flooding occurs at the junction of Deards End Lane with Park Lane EVERY time it rains as the controlling body does not have the funds or the inclination to do anything about it (see attached pictures) and this has been the case for many years. The surface drain at that point is currently 4 inches deep in sludge over the top of the drain hole and plants are now growing there. What hope is there for effective major flood defences elsewhere in the village, particularly if developers are going to asked to pay for it?

The additional infrastructure and alterations needed to cope with your proposed 33% increase in the resident population would have to include; extra car parks, expansion of Knebworth Station car park and ticket office staff and opening times, a new school, library, a new larger village hall, a new bigger doctors' surgery with adequate free parking outside. Building houses on the Chas Lowe site is really inappropriate as this is the most appropriate location for a new doctor's surgery, and new library rather than the restrictive site currently proposed in St Martin's Lane. Very short sighted! The Chase Lowe site should also be fronted by retails units to maintain the sustainability of the village centre.

At present the plan contravenes Strategic objective ECON8 which requires all development to be supported by the necessary provision of improvements to infrastructure, services and facilities. It also contravenes SOC4 which enables rural communities to plan to meet their own local needs, especially through neighbourhood planning.

Many of the objections outlined above have been made to you by many people since early 2015 yet you appear to have ignored them. It is crystal clear that the proposed developments contravene many of your strategic objectives, as well as being out of all proportion to the size of the village and will create major congestion problems. You have also failed to explain how you have calculated the number of new houses needed in this area.

To conform to SOC4 you need to be able to answer the concerns and objections you have received and provide detailed answers to accord with the provisions of ECON 8. Whilst you believe the developers will sort out all these issues raised, you need to be able to justify the housing need, answer concerns of residents over infrastructure etc or go back to the drawing board.

For the above reasons your proposed developments should not go ahead as they are presently drafted.

Object

Local Plan 2011-2031 Proposed Submission Draft

KB3 Chas Lowe site, London Road

Representation ID: 5762

Received: 24/11/2016

Respondent: Mr Andy Nation

Legally compliant? Not specified

Sound? No

Duty to co-operate? Not specified

Representation Summary:

Object to KB3: Loss of employment, retain retail units, better site for library / GP

Full text:

I have been reading the content of your Local Pan for North Herts and can only wonder where your qualified planners were at the time of it's preparation as they seem to have forgotten the very basics of planning.

As I see it, having been a member of the Chartered Management Institute, the process should go something like;
1. Establish where you are now
2. Establish a need, both now and for the foreseeable future
3. Consider the people involved
4. Put in place a viable plan of action that will take you from where you are now to where you need to be, taking into account;
a. Immediate capital projects needed to provide the infrastructure that will facilitate the main aim
b. Materials and funding to complete the project
c. Changes that may become apparent during the course of the project
d. Agreement from all parties involved in implementation

1. Congratulations! It seems you have completed point 1 successfully - up to a point. There are two main problems with the current situation that you have failed to mention;
a. The NHDC and Highways Departments are currently failing to provide adequate flood protection and drainage to the extent that some roads and junctions are dangerous to pedestrians and motorists whenever there is more than just a light rain. Complaints to the Parish Council, our Member of Parliament, Highways and NHDC have received nil response (copies of correspondence can be provided).
b. The lack on maintenance to the back roads of our village has resulted in erosion to embankments and subsequent deterioration the hard metal of the road surfaces at the edges, not to mention the general deterioration of road surfaces across the village, and indeed, across the county.
c. If this current lack of maintenance is due to lack of funding, how can you possibly expect to maintain an even larger housing stock with the subsequent increase in traffic movements?
Overall then, on point 1, it seems you have failed!

2. There were 2002 existing dwellings in Knebworth in 2011. Now you state the need to add a further 663 up to year 2030. That is a 33% increase - or nearly 10 times the 3% actual increase over the last 5 years (65 homes - completions and permissions). Bearing in mind we are only talking of a planning period up to 2030, unless there are factors you are not telling us about, we should only be looking at about 9% increase - 180 houses. Bearing in mind we will soon be exiting the European Union and the Government are committed to securing our borders which should slow down immigration, we may actually see a lesser need over the period. To justify your stated need for 663 new homes the local population would need to breed like rabbits! So on point 2, you have also failed.

3. Let us assume for a moment that most people are not fools. They will, without reservation accept that some development to provide sustainable growth will be required in their village. They will not, however, accept figures and plans thrust upon them without a logical explanation of how they were derived. The fact that some land owners see £ signs in front of their eyes when you ask if they are happy to give up their land for building is not justification for proposing to actually build on all those plots. So once again, on point 3, you have failed.

4. The people (residents) are bound to be concerned when they see proposals that are not backed up by sound planning. Apart from the proposal to provide relatively inadequate additional primary schooling and a possible secondary school (no details) your plans lack any infrastructure details to provide the necessary roads, drainage (both surface and foul - There is a major capacity issue at Rye Meads Sewage treatment Works), local employment opportunity or additional retail facilities. Indeed, you plan to reduce the retail facilities by putting housing on the Chas Lowe site.
At a previous Parish Council meeting The NHDC representative said that no infrastructure details had been included with your Local Plan as "it would be up to the individual house builders to submit proposals for roads, flood mitigation and drainage in their individual planning applications". This is a total abrogation of the Council's responsibility and the villagers will not stand for such a slap-dash attitude towards such a major proposed development. Again, NHDC, your Local Plan has failed.

Now let us consider some of the details, particularly on the west side of Knebworth, that proves your Local Plan is ill-conceived;

Irrespective of your Council's proposed destruction of the greenbelt, you would also be acting against your own 2006 study which stated that "Knebworth is not suitable for further development as it would risk the sustainability of the village". Nothing has changed since then so it seems you make sound-bites to suit yourselves!

There are two Conservation Areas adjacent to the proposed development areas; Stockens Green & Deards End Lane, which NHDC is responsible for maintaining. Allowing dense house building so close to these areas would go against NHDC's own publicly stated policy regarding the sites' importance, which includes a section of Park Lane. Furthermore Core Strategy EN2 Covering Protection and Enhancement of Landscape and Settlement Character states that development proposals should demonstrate that their location, scale, design, and materials will protect, conserve and, where possible enhance: The setting of, and views from Conservation areas. Therefore building a high density housing estate next to these conservation areas would contravene Core Strategy EN2 by ruining their setting and views. The Strategic objectives ENV1, ENV2, ENV3 and ENV5 will also be contravened by such a huge scheme in relation to the present size of Knebworth.

Access to these two sites, has to be via one of 4 narrow railway bridges, 3 of which have limited vision, which are pinch points and already cause congestion and accidents. Unless the railway bridges are widened the congestion will get worse. However, widening these bridges and straightening the approaches is not a viable option, especially the one at Deards End Lane. The best of the 4 bridges is the one at Woolmer Green but the road to the west of it is a single track along Wych Elm Lane between open fields

Deards End Lane and Gypsy Lane are already too heavily used by traffic between Stevenage & A1(M), and Codicote, Whitwell, Wheathampstead, Harpenden, Luton and Welwyn. These roads are too narrow to accommodate two way traffic along much of their length. Already, erosion to the verges, drive entrances and the edge of the carriageway testify to this with many potholes. Many of the entrances to these properties are blind making it difficult for residents to exit as well for cars using the road. The resulting increase in traffic on these roads would not only lead to further deterioration of these lanes, and the fact they lack any pedestrian pathways would undoubtedly lead to increased pedestrian accidents. This danger to pedestrians through lack of pathways and flooding is a constant concern as vehicles have been monitored along Deards End Lane at over 40 miles per hour. Pedestrian accidents have been reported to the Police and the Council but requests to introduce a 20 miles per hour speed limit have either been flatly refused "until someone is killed", or been pushed from pillar to post - each department denying it is their job.

Widening these roads, particularly Deard's End Lane, would totally destroy the character of this conservation area and would be totally unacceptable. The proposed developments would require new access points to be arranged off the B197 and the A1(M) B197 south and north of Knebworth to provide a bypass for Knebworth and for access to the developments west of Deards End Lane and Gypsy Lane. This would be essential before any development could possibly begin.

You have mentioned in your plan regarding Knebworth "the High Street is a known pinch point, particularly when delays or incidents on the A1(M) result in the B197 being used as
an alternate route between Welwyn Garden City and Stevenage." With just a modicum of joined up thinking for the future, this problem can be partially relieved by bypassing Knebworth with a relief road. I would propose you consider the following;

The bridge at Bridge Rod, Woolmer Green is the only bridge offering reasonable access to the west of Knebworth. So;
1. Put a roundabout at the junction B197/Bridge Road
2. Improve the road Wych Elm Lane by widening and straightening slightly up to Gypsy Lane
3. From where Gypsy Lane veers away from being next to, and parallel to, the A1(M) motorway, make a new road continuing parallel to the motorway, through your proposed Gypsy Lane development site, to meet and cross over Park Lane at a mini roundabout.
4. Continue the new road parallel to the motorway, through your proposed development site to the west of Deards End Lane Conservation Area, continuing along the very west fringe of Knebworth Golf Course (which would not interfere with their fairways), to cross over Old Knebworth Lane at a mini roundabout.
5. Continue the new road parallel to the motorway, through the west side of the proposed Science Park to meet the A602.

This proposal would address a whole host of problems;
* Pinch point at Knebworth High Street
* Access to the west side of Knebworth
* Relief road in the event of A1(M) closure between Stevenage south and Welwyn
* Congestion at peak times for traffic accessing the B197 from the A602
* Now that QEII Hospital A&E has been closed, emergency ambulances would have a shorter time to reach Lister Hospital in the event of traffic congestion
* Traffic from Welwyn west, Whitwell and Codicote and all points west would have easier access to Stevenage and beyond
Failure to adopt this proposal would be a major reason for your proposed development west of Knebworth to fail. Proposals 1 - 4 above would be the minimum to justify ANY development west of Knebworth.

I continue to give details below, not just about your justification, or lack of, for the density of your proposed housing but also the need for such housing.
Some of the low lying houses in Orchard Way and Broom Grove are already subject to flooding after heavy rain from excess run off from the fields to the west. Flooding is also a problem in
the High Street and Pondcroft Road where sandbags have to be used to block doorways during heavy rain. Some of the existing drains are blocked by stones and gravel. Covering those fields (052) with concrete would only make matters worse. No details are given of what type of sustainable drainage systems would be needed for preventing flooding of parts of Knebworth are included. It would certainly have to be a large system such as a flood run-off storage reservoir near the middle of the new development where the ground slopes down, to control the flooding of parts of Knebworth including Orchard Way and Broom Grove. Flooding occurs at the junction of Deards End Lane with Park Lane EVERY time it rains as the controlling body does not have the funds or the inclination to do anything about it (see attached pictures) and this has been the case for many years. The surface drain at that point is currently 4 inches deep in sludge over the top of the drain hole and plants are now growing there. What hope is there for effective major flood defences elsewhere in the village, particularly if developers are going to asked to pay for it?

The additional infrastructure and alterations needed to cope with your proposed 33% increase in the resident population would have to include; extra car parks, expansion of Knebworth Station car park and ticket office staff and opening times, a new school, library, a new larger village hall, a new bigger doctors' surgery with adequate free parking outside. Building houses on the Chas Lowe site is really inappropriate as this is the most appropriate location for a new doctor's surgery, and new library rather than the restrictive site currently proposed in St Martin's Lane. Very short sighted! The Chase Lowe site should also be fronted by retails units to maintain the sustainability of the village centre.

At present the plan contravenes Strategic objective ECON8 which requires all development to be supported by the necessary provision of improvements to infrastructure, services and facilities. It also contravenes SOC4 which enables rural communities to plan to meet their own local needs, especially through neighbourhood planning.

Many of the objections outlined above have been made to you by many people since early 2015 yet you appear to have ignored them. It is crystal clear that the proposed developments contravene many of your strategic objectives, as well as being out of all proportion to the size of the village and will create major congestion problems. You have also failed to explain how you have calculated the number of new houses needed in this area.

To conform to SOC4 you need to be able to answer the concerns and objections you have received and provide detailed answers to accord with the provisions of ECON 8. Whilst you believe the developers will sort out all these issues raised, you need to be able to justify the housing need, answer concerns of residents over infrastructure etc or go back to the drawing board.

For the above reasons your proposed developments should not go ahead as they are presently drafted.

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