Local Plan 2011-2031 Proposed Submission Draft

The Parish Council objects to the amount of housing development proposed for the village of Knebworth, and the lack of a strategy for the area. The four sites specified would increase the numbers of dwellings by 31% an increase which is proportionately greater than most other Category A settlements in North Hertfordshire. The rate of development proposed is well in excess of that experienced in recent decades. What has been proposed amounts to a housing "monoculture" - there is nothing proposed for local employment development.
No account has been taken of the recent planning permission for housing (70 dwellings) on the Odyssey former health centre site, adjacent to the Stevenage boundary at the Roebuck. The Parish Council notes that this site was rejected in the 2016 SHLAA Update. In addition, the Plan needs to recognise the impact of the proposal in the Welwyn Hatfield draft Local Plan (Policy HS15) for 150 dwellings at Woolmer Green, to the south of the Knebworth Parish Boundary.

The detailed concerns are set out in the responses to the individual sites, but there are cumulative effects on the whole Parish which need to be addressed. These issues are set out below.

1. Green Belt

The proposals to release land form the Green Belt are based on the Green Belt Review of July 2016. Compared to the earlier 2014 Review, this has intentionally treated Knebworth differently - as an urban area, rather than a village. Undoubtedly, this has resulted in the disproportionate allocation of housing land to Knebworth. The assumptions underlying this analysis, and its conclusions, are flawed and the Plan is unsound.

Sites KB1, KB2, and KB4 are entirely within the Green Belt which surrounds the village. Development of these areas would be contrary to Government policy as set out in the National Planning Policy Framework (NPPF). Paragraph 83 of the NPPF states that Green Belt boundaries should only be altered in exceptional circumstances.
In our view, the District Council has not demonstrated exceptional circumstances for the release of substantial areas of Green Belt land. In this part of Hertfordshire, the Green Belt fulfils many of the purposes set out in the NPPF (paragraph 80). This is acknowledged in the NHDC Green Belt Review Update (July 2016).
As part of a more widespread strategic function the Green Belt does help to check the unrestricted sprawl of Greater London along the main route corridors in Hertfordshire. This principle was established in the Hertfordshire County Structure Plan, which was approved by the Government in 1979. The NHDC Green Belt Review also considers that it contains the outward sprawl of Stevenage.

More locally, the Green Belt does prevent neighbouring towns from merging into one another. Thus the gap has been maintained between the village of Knebworth and Stevenage to the north, as well as Woolmer Green to the south.
It also assists in saving the countryside from encroachment, a particularly important function in a vibrant county such as Hertfordshire. Arguably, it has also assisted in urban regeneration by channelling economic development into Stevenage and other towns.

These points are acknowledged in the NHDC Green Belt strategic assessment of the existing Green Belt. For Knebworth, the parcels of land around the village are considered to make a significant contribution to Green Belt purposes.

According to the earlier 2014 Green Belt Review, all of the sites around the village were stated to be significant, with one exception - the land to the south of Swangley's Lane. Despite this conclusion, the sites to the west of the village (now KB1 and KB2) were recommended for allocation.

With addition of the sites to the east of Knebworth in the 2016 sites review, it is unclear why and how the District has seemed to cast aside the results of its own reports.

The Odyssey site was considered in the 2016 SHLAA Update (site 54) as unsuitable for development, in order to protect the "clear defensible Green Belt boundary to the southern edge of Stevenage". Yet this site was approved for housing development by North Hertfordshire District Council Planning Control committee on 13th October 2016 (application number 16/00813/1), thus further threatening the Green Belt gap between Knebworth and Stevenage.

2 Highways and Transport

The Parish Council is extremely concerned about the cumulative impact of the four development sites on the highways network in and around the village of Knebworth. The detailed effects are considered in the representations on the individual sites, but it is inevitable that the additional traffic generated by the proposals would be channelled onto the B197, which runs from north to south through the centre of the village. This already a busy thoroughfare, with severe congestion occurring in the main shopping centre, where there is conflict between through traffic and car parking movements. The problems are exacerbated on occasions when the A1 (M) is closed and the B197 is used as a diversionary route, also at peak times when the motorway is overloaded.

With regards to the proposals on the west side of the village, there appears to be an underlying assumption that there are three bridges crossing the East Coast main railway line, and therefore traffic movements can be accommodated with some improvements. This downplays the reality of the problems. All three bridges are narrow and cause traffic delays and safety concerns. To the south, in the Parish of Woolmer Green, there is also a fourth bridge at Bridge Road, which would also be affected by additional traffic generated in Knebworth. For any improvements to these four bridges, there would be the question of the impact on railway traffic during construction.

As cars have increased in size, it has become extremely difficult for opposing vehicles to pass safely through the bridges at any one time. The problems is particularly acute at the under-bridges at Bridge Lane and Gun Lane. It is hard to envisage how improvements could be made without wholesale widening of the structures. This would be undesirable with regards to the under-bridge at Gun Lane, which forms the entrance to the Stockens Green Conservation Area. This bridge is also located on a tight bend close to adjoining housing. Little consideration appears to have been given as to how any improvements could be delivered in terms of the impact of construction work on railway traffic on the East Coast main line.
In addition to the effects on the bridges, the Parish Council is concerned about the effects on the local roads. Much of the traffic from sites KB1 and KB2 will pass through Deards End Lane (the shortest route to the north). Traffic from these sites seeking the B197 to the south will either use Gypsy Lane/Wych Elm Lane/ Bridge Lane or Gypsy Lane/Stockens Green.

As a result of these movements, there would be a seriously detrimental effect on the character of the two Conservation Areas and the amenity of local residents. Deards End Lane in particular is a narrow hedged road with no footpath, bounded by residents' gardens. There would appear to be no viable solution to the concerns about congestion and safety.
Similar concerns are raised in relation to site KB4 and the potential impact on Watton Road and Swangley's Lane. (see representation ID278).

3. Economy and Employment

The Parish Council strongly objects to the concentration on housing development in the Local Plan proposals for Knebworth, with no provision for employment. In fact the development of the Chas Lowe site (KB3) would result in a net loss of employment in the Parish. This lack of balance is unsustainable.

4. Drainage

The Parish Council submits that the cumulative effects of the proposed developments would place severe pressures on drainage infrastructure, a problem which is acknowledged by the District Council in paragraphs 13.201 and 13.202 of the Local Plan. It is not enough to state that "scheme promoters should work with Thames Water".
This ignores the fact that the Rye Meads sewage treatment works deals with waste from a considerable catchment area. Within this catchment, there are a number of local planning authorities preparing Local Plans for submission. All of these plans contain proposals for large-scale housing development. Cumulatively, these developments cast doubts on the capacity of Rye Meads to deal with the waste which would be generated. This problem has not been addressed on a sub-regional basis. Knebworth is on the edge of the Rye Meads catchment area, and it is therefore extremely unlikely that housing could be delivered because of the real constraints on drainage capacity.

5. Impact on the Countryside

Knebworth is set within an area of attractive countryside. The village is contained within a bowl of undulating landscape. The proposed developments would cause considerable harm to this landscape setting. In doing so, large areas of productive farmland would be lost, contrary to paragraph 112 of the NPPF, which seeks to protect the areas of best and most versatile agricultural land.

6. Conservation and Heritage

The village of Knebworth has two Conservation Areas, the character of which would be effected by the proposed developments. The details are described in the responses to the individual sites.

7. Education
It is noted that the proposals for KB2 include provision for a IFE Primary School. Proposals for KB4 also contain 4Ha of land for education. Taken on their own, the proposed housing numbers on each of the development sites fall below the HCC threshold for additional school provision, which is approximately 500 dwellings. This gives rise to a concern as to whether the developers of individual sites would be willing to fund additional education provision.

The Parish Council objects to this site principally because it is in the Green Belt , thus its development would be contrary to government policy as set out in the NPPF. North Hertfordshire District Council have not demonstrated that "exceptional circumstances" exist for the development of the site. This particular tract of Green Belt is important because it prevents the encroachment of Knebworth into the countryside to the west.

The site is located between the A1(M) and the western edge of Knebworth Village and is affected by traffic noise from the A1(M). The adjacent stretch of the A1(M), between Junction 6 and 7, is poorly-rated in the recent Highways England report (A1 East of England Strategic Study, June 2016). There are high levels of congestion, accidents, and noise. There is a proposal to create all-lane running on the motorway, by removing the hard shoulder, but Highways England consider that this may generate additional demand for use of the motorway and local roads. The impact of the A1 (M) on the Knebworth area, therefore, can only get worse. For the longer terms future, the building of housing on this site would impact on the future viability of any plan to widen the A1(M). Such a scheme cannot be ruled out, given that this section of the A1(M) is one of the most heavily-congested in the UK.

In the Local Plan, the Council suggest noise mitigation measures, but the noise levels are unlikely to drop and any mitigation measures would most likely reduce the size of the development area. The Green Belt designation of this area does constitute an effective noise buffer between the A1(M) and the village.

The amount of traffic generated by about 200 new dwellings would add considerably to the levels of traffic impacts on the B197. Congestion levels in the centre of the village would be exacerbated. There would also be pressures on the Deards Lane End Lane railway over-bridge, which is a Scheduled Ancient Monument. Increases in traffic are likely to have an adverse effect on the structural integrity of the bridge, which crosses the East Coast main railway line.

To the east of the site is the Deards End Conservation Area, the character of which would be severely affected by the proximity of so much new housing and the increased levels of traffic. With a potential link to Park Road, and north-south movement through the village limited by three narrow railway bridges, there is a clear risk that a "rat run" would be created by drivers seeking to access Stevenage from both KB1 and KB2. Deards End Lane is a narrow single track road with no pavements, giving rise to safety concerns for all road users as well as pedestrians. Complaints about the volume and speed of traffic have already been raised by local residents.

The infrastructure improvements suggested by the District Council are impracticable. Any road widening would have an adverse effect on the character of the Conservation Area, and would involve the loss of residents' gardens. For these reasons, the delivery of KB1 is highly questionable.

There is also concern about the potential effect on the Knebworth Woods SSSI, to the west of the proposed development, and an area of ancient woodland adjacent to the site. Both areas are protected habitats and the impact of the development would have to be assessed against the provisions of the NPPF (paragraphs 14, 113 and 117).

The Parish Council objects to the development of this site, principally because it is designated as Green Belt. The Green Belt performs an important function in this location because it prevents the encroachment of Knebworth Village into the open countryside to the west. It also provides an effective noise buffer between the A1(M) and the village.

To the east of the site is the Stockens Green Conservation Area, the character of which would be severely affected by the amount of housing and the amount of traffic which would be generated.

The Local Plan acknowledges that the volume of traffic would have an adverse impact on the Gun Lane railway bridge, which is narrow and unsuitable for increases in traffic. This is a major concern, as it would provide the main entrance to the development area from the east. Any improvements would affect rail traffic, and thus could affect the deliverability of development.

The proposals would also have a major impact on Gypsy Lane and adjoining residential roads. As with KB1, it should be noted that concerns about the speed and volume of traffic using this road are among the complaints most often raised by local residents.

The development would be bounded to the west by the A1(M) which generates high levels of traffic noise. Noise mitigation measures are proposed in the Local Plan, but these likely to reduce the size of the developable area.

Currently the site contains a balancing pond which takes surface water draining from the A1(M). It is recognised that there are surface water flood risk issues on the site, which cannot be resolved by SUDs alone.

A 1FE primary school is proposed for the site. It is questionable whether a school should be proposed in an area so close to a busy motorway. The ultimate viability of this proposal, however, depends on whether other sites (KB1 and KB4) are allocated in the Local Plan. The target of 184 dwellings is well below the County Council threshold for the provision of primary schools, which is approximately 500 dwellings.

The Parish Council objects to the proposed development of this site for housing, principally because it would remove an important source of employment and business from the local economy. Proposed development of this site contravenes the District Council's own policy in the Local Plan (policy ETC2), which seeks to protect employment on non-allocated sites. Allocation for housing would actually reduce the amount of land zoned for commercial use in this part of North Hertfordshire.

The site is a key location in the centre of the village. In terms of its activity, it contributes much to the character of Knebworth. There is no analysis of justifiable alternatives in the Local Plan, to off-set the loss of this site to the local economy. There has been speculation about the future of Chas Lowe on this site, but the Parish Council believes strongly that there should be no loss of retail and commercial use on this key site in the centre of the village. It should be noted that policy SP4 and paragraph 4.37 of the Local Plan clearly support town and local centres, including Knebworth. It not clear how the District Council intends to deliver this policy in Knebworth or any of the other local centres.

In recent years there have been problems in this part of the village with flooding associated with poor surface water drainage. The Parish Council is concerned that the construction of housing on this site would exacerbate the risk of flooding, due to increased surface run-off.

The Parish Council strongly objects to the development of this area principally because it is designated as Green Belt. The Green Belt performs two important functions on the eastern side of Knebworth. First, it prevents the encroachment of the village into the surrounding countryside. Second, it protects the gap between the edge of Stevenage to the north and east, thus preventing the coalescence of the two settlements. The existing development boundary is soundly defined on the ground, beyond which is open countryside.

The tract of countryside to the east of the village, on rising ground, provides a significant open landscape setting for Knebworth which would be compromised by the extent of the proposed development area. There are long views into and out of the village which add much to its overall character. The views from the village recreation ground are significant and would be severely restricted by the proposed development. Most of the KB4 land is actively-farmed and its loss to development would be contrary to the NPPF (paragraph 112), which seeks to protect the best and most versatile agricultural land.

The amount of traffic generated by the development would have an adverse effect on the capacity of the B197 route thorough the village. More locally, it would severely affect the character and capacity of Watton Road and Datchworth Road. Both these roads are narrow and winding and are damaged by "rat-running" traffic seeking to avoid congestion on the B197 and the A602, as well as the A1(M). This contravenes the Hertfordshire Local Transport Plan 2011 (LTP3), which seeks to protect rural roads. With the development of KB4, these problems can only get worse.

It should be noted that Watton Road is already problematic in that it is used as a "rat run". At the west end, it has been necessary to introduce traffic calming measures to slow traffic through the residential area. Old Lane was formerly heavily used by traffic seeking to avoid the village centre, but has now been closed to south-bound traffic.

In recent years there have been problems with excessive surface water flooding on the east side of the village. This will be exacerbated by the proposed housing development which cannot be overcome by SUDs alone. The problems of sewage disposal and drainage capacity have been summarised in the Parish Council's general representations on Knebworth.

No additional schooling is proposed for this site, but it is acknowledged (in paragraphs 13.190 - 13.194) that there could be a deficiency in school places, particularly if all four sites in Knebworth were developed. This would also apply to secondary education, which is not currently provided in the village. There is speculation about the provision of an "all through" school, but no concrete proposal. The District Council states (in paragraph 13.194) that it "will work with Hertfordshire County Council and the Parish Council" to provide "the most appropriate education solution for the site" but there is no firm plan and no guarantee of delivery.
There is already a problem with the provision of secondary education for Knebworth. Recently, there was an application to build a "free" school in the village but this was rejected by the Secretary of State at an early stage. There is clear evidence that he village is under-served in terms of secondary education, a problem which would be compounded if the proposed developments were to be include in the Local Plan.

The Parish Council supports this policy and the principles which underlie it. Application of this policy, however, depends on the detailed policies and proposals set out elsewhere in the Local Plan.
These points are elaborated in the Parish Council's representations on specific sections of the Local Plan, particularly on Knebworth.
For example, Policy SP1(c) (I) states that the District Council will "deliver and appropriate mix of homes, jobs, and facilities." In Knebworth, this is not embodied in policies KB1 - KB4, which are concerned with the delivery of housing and no employment. In fact the implementation of policy KB3 would result in the removal of a key employment site in the middle of the village. This is not sustainable.
Policy SP1 (d) pledges the District Council's support for Neighbourhood Plans. In our view, this has not been delivered in the four years since the launch of the Government initiative on Neighbourhood Plans.
The District Council's approach needs to be strengthened to give a more positive encouragement to town and parish councils and other qualifying bodies. For example, in East Hertfordshire, the recently-published District Plan contains a policy which devolves the responsibility for housing allocation and detailed local planning policy to town and parish councils in Group 1 settlements through Neighbourhood Plans. It is recommended that this approach should be adopted in North Hertfordshire. This would ensure that the scale and mix of development provided in Category A villages is appropriate to the size and status of the settlement and is endorsed by the local community.

The Parish Council is concerned that no account appears to have been taken of the recent Knebworth Parish Plan, which was published in 2007. This does set out some clear guidelines on the character of the area, the constraints and opportunities for development, and the aspirations of the local community.

The Parish Council generally supports this policy and the settlement hierarchy for the District. It supports the designation of Knebworth as a Category 1 settlement in line with the principles described in paragraph 4.13. Comments on the detailed policies for Knebworth are set out in our representations elsewhere.

The Parish Council also supports the intention (paragraph 4.11) to focus the majority of development on towns and urban extensions.

Some detailed changes to the policy wording are suggested. In the first part of policy SP1, on Stevenage, the reference in the bracket should state ("including Great Ashby and west of Stevenage") The reasoning for this is set out in our comments on the strategic housing sites.

In the second part of the policy, it is recommended that the introductory wording should be changed to read as follows:
" General development will also be permitted in the defined settlement boundaries of Category A villages. The amount of development shall be specified in Neighbourhood Plans, to be prepared for each of the settlements. Provision for housing shall be not less than 10% of the number of dwellings in the 2011 Census returns. The Category A villages are:....."

The Parish Council supports policy SP4 and paragraph 4.42 of the Local Plan. The village centre is a vibrant and lively trading environment, serving not only the village but also a wider rural area. There are no vacant units, but there are concerns about traffic congestion on the B197 and car parking, which is concentrated on the main street. These are addressed in our representations on Knebworth (Policies KB1 - KB4).
The current plans for a new library, doctors' surgery, and pharmacy are welcomed and should assist in supporting the future viability of the shopping centre.
It is not clear, however, how the District Council intends to deliver this policy, particularly with reference to the Local Centres, including Knebworth.

The Parish Council objects to policy SP8 and the District Council's housing strategy, which is set out in paragraphs 4.85 - 4.112 of the Local Plan. The objectively-assessed needs for housing have recently been updated for the District Council in the report Updating the Housing Need (ORS, 2016). This leads to the assumption in policy SP8 that the Local Plan should provide for at least 14,000 dwellings in the plan period. The This in itself is questionable. The District Council does not have to accept this figure, particularly in those parts of the area which are designated as Green Belt. It is noted from the 2016 SHLAA Update that 63 sites are allocated in the Green Belt, amounting to 12,722 dwellings.

The allocations of land are based substantially on the results of the SHLAA, which has also been updated. The methodology results in a "scatter gun" pattern of development across the rural areas of the District. In village such as Knebworth, proposed housing allocations are way in excess of the capacity of the settlement to receive the amount of development.

In our view, the overall strategy is flawed and should be changed. In the SHLAA and in paragraph 4.104 of the Local Plan, a potential strategic development site has been identified to the west of the A1(M) at Stevenage. Most of this site lies within North Hertfordshire, and it was originally specified for development in the draft Hertfordshire Structure Plan Review of 1996. It was subsequently included in the East of England Plan, which was abandoned by the government in 2012.

Over a period of years, a considerable amount of work was done on the planning of this site. Initially, it was supported by the County Council, but this was withdrawn following a change of political control at County Hall. Nevertheless, a consortium of developers was formed to deliver the development via a Master Plan. Although the proposal was withdrawn with the demise of the Regional Plan, a considerable amount of detailed work was done. In our view, this means that the project could be revived in a short period of time. With a capacity of 3,100 dwellings, the site could make a major contribution to satisfying the dwellings requirements for North Hertfordshire in the plan period.

The inclusion of this site in the Local Plan (policy SP8) as a Strategic Housing Site would mean that 10,800 dwellings could be provided from seven sites. Thus, the requirement for local housing provisions could be reduced form 4,860 to 1,760 dwellings. The bulk of this development would be provided in the 21 Category A villages, via Neighbourhood Plans to be prepared by town and parish councils with the assistance of the District Council policy team.

The consequent changes to policy SP8 and the accompanying text are set out below.