Representation for Land Allocations: Additional Suggested Sites July 2009 Knebworth Ref . Rep No . Applicant Agent 0398 9 Knebworth Estates Document Section :Knebworth Representation : Comment This letter is my response, on behalf of Knebworth Estates, to the Local Development Framework's Additional Suggested Sites Consultation. I appreciate you prefer to receive responses in electronic form, therefore I have also separately emailed the text of this letter. Much of what is relevant to our representation has been made in previous representations by Knebworth Estates to previous LDF Consultations, including the 'Core Strategy and Development Control Polices, Preferred Options' Consultation (Oct '07) and the 'Land Allocations: Issues and Options' Consultation (March '08). Rather than repeat the evidence previously submitted, I ask that this representation is read in conjunction with these previous responses. Regarding all 126 additional sites - Knebworth Estates asks Council to be led by the key principal of Ebenezer Howard that Hertfordshire's urban spaces should be a blend of city and nature. Although Greenbelt is much valued, our urban communities should not be sacrificed at its expense. Turning every garden into a house and every house into flats, and clogging up our town centres, is too great a price to pay for protecting Greenbelt ¿ and I suspect, in the future, will be seen as the great planning disaster of our generation. Much better for our towns, villages, hamlets and countryside to all play a part, and evolve in a balanced way. Regarding the Knebworth village-edge sites (52, 53, 55, 57 & 58), it is disappointing that officers have chosen to consult on village-edge sites only to the east and the west, and not on village-edge sites to the north and south, which, as put forward in the 'Knebworth Sites Appraisal Report' (Dec '07 & previously submitted) are better connected to the B197 and would require less access through the middle of the village. If Site 57 is chosen, we ask that consideration is given to the possible future need to enlarge Knebworth Junior school, which would become development landlocked were this site to be re-designated for residential use. Regarding Sites 52 & 53, we ask Council to consider the unique opportunity presented by Knebworth Estates' published offer (Knebworth Parish Council's 'Knebworth Sites Appraisal Report' - Dec '07, paragraph 3.10, p.10) that 'if residential development was required at Knebworth's village edge by the LDF, it would look to donate the proceeds to Parish Charities as long as the Knebworth House Education and Preservation Trust was a priority.' Knebworth Estates remains committed to donating 100% of any proceeds from either or both of these two sites resultant from residential re-designation by the LDF. Any residential re-designation of these sites would produce substantial charitable sums for, not only the Knebworth House Education and Preservation Trust, which is critically under-endowed and has previously established itself as a 'very special circumstance' in Enabling Development and Greenbelt policy; but also for the benefit of Knebworth Village, which faces serious challenges highlighted by its Parish Plan (April '07) which are (and are likely to remain) beyond local authority budgets, and yet which will threaten the village's sustainability (the loss of its doctors, shops and services). This is a unique opportunity to solve long-term community problems, whilst at the same time answer district and regional needs within the Local Development Framework. Paragraph 3.64 of the LDF'S Core Strategy Preferred Options document of September '07 states: 'Knebworth is probably the most sustainable village in the district and therefore should be allowed to grow a modest amount to take advantage of the existing facilities. This may require additional investment, notably in the village school, which is operating close to capacity.' The offer mentioned in the above paragraph provides possible 'additional investment ' way in excess of Section 106 or other standard developer contributions, and can easily be imagined to solve any other arising infrastructure issues, including sewage (mentioned as a concern elsewhere in the September '07 document). Beyond a local self-sustaining sewage system, sewage is a district-wide issue and not Knebworth specific. If only a section of Sites 52 & 53 is thought necessary or appropriate for re-designation, Knebworth Estates favours re-designation at the southern end of the combined sites, for reasons given in the last paragraph of our March '08 representations on Land Allocations, that put forward the South Knebworth Field site (Site 5 in the 'Knebworth Sites Appraisal Report' - Dec 07) as the best option should village-edge development be required. Regarding the non-village-edge Knebworth sites, if Site 54 is chosen, Knebworth Estates strongly supports the moving of the site entrance from Old Knebworth Lane to the B197. 0964 2 Cousins Document Section :Knebworth Representation : Object Please find below my comments on the North Herts District Council land allocations additional suggested sites dated July 2009 specifically in connection with the promotion of seven Printed: 01/03/2010 12:25:01 Representation for Land Allocations: Additional Suggested Sites July 2009 Knebworth Ref . Rep No . Applicant Agent green belt sites located on the edge of Knebworth (sites 52-58 inclusive). Please note I have no over-riding objection to the allocation of site 54 in view of the leisure and recreation use being promoted particularly as it is a brownfield site with established built form. I am however, concerned at the additional sites proposed for housing on Green Belt land. National Planning Guidance (PPG2: Green Belts) states in paragraph 1.4 the fundamental aim of Green Belts is to prevent urban sprawl, therefore without exception all these sites, as they are located outside the defined settlement boundary of Knebworth would extend the village. Paragraph 1.5 indicates the purpose of land in the Green Belt is to prevent neighbouring towns from merging. Knebworth is located less than a mile from Stevenage in a southly and westerly direction with Woolmer Green less than half a mile to the south . Any extension of Knebworth would erode the gap with Stevenage and Woolmer Green and create coalescence diminishing the open nature of the countryside around the village. (Paragraph 1.4 states the most important attribute of Green Belts is their openness). Paragraph 1.6 promotes the positive role of Green Belts to retain land in agricultural use. All these sites are for such use and there is no justification provided to support their loss. Paragraph 2.9 notes Green Belts should be several miles wide to ensure an appreciable open zone around built up areas. The Green Belt is already less than one mile wide and therefore no development should take place on the edge of Knebworth as the gap between settlements would inevitably be narrowed even further. There is a general acceptance the Council will need to release some land located in the district from the Green Belt to meet future housing needs and due consideration will need to be given as to where this is located. Other towns located in the district are characterised by a wider range of facilities and services that can be more readily be extended to cope with additional demands imposed by development. The site descriptions within the sustainability appraisal note the identified constraints on utilities and schooling in the village, therefore promotion of Knebworth for extension by way of Green Belt release is a flawed concept. Stevenage with its extensive range of services and community facilities offers the opportunity to consider urban extension and initiatives being actively promoted by North Herts District Council e.g The Stevenage and North Herts Area Action Plan (SNAP) provide a much more sustainable approach to the release of Green Belt land than any extension of Knebworth. The additional Knebworth sites offer no justification as to how a number of constraints will be overcome: 1. The free and easy flow of traffic along the 'High Street' including the resolution of issues related to commercial traffic created by Chas Lowe's operation which is in the process of extending to additional premises. 2. Location of development immediately adjacent to the A1 (M). 3. The rural nature of roads that serve the village from easterly direction e.g Swangleys Lane which is wholly unsuitable for additional traffic, being narrow and barely capable of permitting two cars to pass each other and importantly a primary school close to its junction with London Road. In summary, I oppose the extension of Knebworth through the release of Green Belt land. 0985 5 Trotman Document Section :Knebworth Representation : Object Thank you for your letter of 16 July 2009 requesting my views on the above reference sites. The following comments refer to the seven Knebworth sites with particular emphasis on those five sites surrounding the village. Printed: 01/03/2010 12:25:01 Representation for Land Allocations: Additional Suggested Sites July 2009 Knebworth Ref . Rep No . Applicant Agent 1. General Knebworth is already a well established balanced sustainable village with shops, schools, services, infrastructure and a good mix of social, affordable, mid and upper priced homes. Any significant additional developemnt would jeopardise and destabilise the community with pressure on schools, services , infrastructutre e'g sewers, roads (parking already a nightmare). The suggested five greenfield sites surrounding thr village, if developed with the potential of some 1300 dwellings, would totally devastate and change the character of Knebworth from a village to a small urban town and to paraphrase Prince Clarles "be disfigured by five carbuncles on the face of an old friend". I therefore support the current NHDC planning Policy for Knebworth theat there should be no incursions into the green belt surrounding Knebworth. The NHDC cooporate plan states "that it will protect the environment by vigorously challenging airport and green-field housing development".