CONSULTATION STATEMENT March 2021
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Table of Contents
1 Introduction 6 1.1 Introduction 6 1.2 Aims 6 2 List of Consultations undertaken 7 3 Individual Consultations 9 3.1 Announcement of proposal for a Neighbourhood Plan – May 2016 9 3.1.1 Outcomes: 9 3.2 Household Survey Preliminary work – November 2016 9 3.3 Household Survey - January 2017 9 3.3.1 Key issues identified from the results: 9 3.3.2 Action Taken: 10 3.4 Presentation at Annual Parish Meeting – May 2017 10 3.5 Liaison with Hertfordshire Constabulary – September 2017 10 3.6 Liaison with Scout & Guide Group – October 2017 10 3.7 Knebworth Youth Project (youth club) – October 2017 10 3.8 Children Centre provision (Early Years 0-5) – November 2017 11 3.9 Safety and Security - Neighbourhood Watch – September 2017 11 3.10 Hertshelp service – December 2017 11 3.11 Adjacent Parish Newsletters – December 2016 to date 12 3.12 Surgery Practice Manager – September 2017 to date 12 3.13 Patient Participation Group – September 2017 to date 12 3.14 Community Library Committee – September 2017 to date 12 3.15 Knebworth Guide Group – September 2017 to date 12 3.16 Chairman of Knebworth Football Club – September 2017 to date 13 3.17 Great Ashby parking survey – March 2018 13 3.18 Housing Needs Survey – April 2018 13 3.19 Public Open Days – 19th and 21st April 2018 13 3.19.1 Publicity 13 3.19.2 Posters 13 3.19.3 Key issues raised: 15 3.20 Presentation at Annual Parish Meeting – May 2018 16 3.21 Sport & Leisure Survey – June 2018 16 3.22 Schools Engagement – 19th June 2018 16
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3.23 Local Business Survey – July 2018 17 3.23.1 Main issues raised: 17 3.24 Local Councillor Surgery – 14th July 2018 17 3.25 Meeting with local councillor – 17th July 2018 17 3.26 Youth Focus Group - 18th October 2018 18 3.27 Knebworth Parking Survey – October 2018 18 3.28 Meeting with main Landowners – 14th November 2018 18 3.29 Estate Agent survey – December 2018 18 3.30 Meeting with main Landowners – 31st January 2019 19 3.31 Meeting with main Landowners – 1st March 2019 19 3.32 Public Open Day – 2nd March 2019 19 3.32.1 Publicity 19 3.32.2 Format 19 3.32.3 Outcomes 21 3.33 Presentation at Annual Parish Meeting – 1st May 2019 23 3.34 Meeting with NHDC Senior Planning Officer – 29th May 2019 23 3.35 Review of Consultation Statement – 10th July 2019 23 3.36 Regulation 14 Consultation – March to May 2020 24 3.36.1 Background 24 3.36.2 Delivery 24 3.36.3 Responses 25 3.36.4 Analysis of Responses 25 3.36.5 Statistics 26 3.37 Action Plan 26 Appendix A Household Survey 27 Appendix B Text of Parish Meeting Presentation 29 Appendix C Great Ashby Parking Survey 30 Appendix D Great Ashby Parking Survey Data 31 Appendix E Housing Needs Survey 32 Appendix F Housing Needs Survey data 36 Appendix G Example of Open Day displays 37 Appendix H Sport and Leisure Survey 38 Appendix I Agenda for Pupil Parliament Exercise 40 Appendix J Local Business Survey 41 Appendix K Business Survey Graphs and Summary 43 Appendix L Young People’s Survey 45
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Appendix M Knebworth Parking Survey Output 47 Appendix N Estate Agent Survey 50 Appendix O Feedback from Open Day 51 Appendix P Responses from Regulation 14 Consultation resulting in an amendment 52 Appendix Q Action Plan 125
Table of figures
Figure 1 Presentation to Youth Project ...... 11 Figure 2 Engagement exercise ...... 11 Figure 3 Open Day Poster ...... 14 Figure 4 Local newspaper article ...... 14 Figure 5 Example title strip for display ...... 14 Figure 6 Example of displays ...... 15 Figure 7 Visitors at the Open Day ...... 15 Figure 8 Members of the Steering Committee engaging with visitors...... 16 Figure 9 Display of policies ...... 20 Figure 10 Map showing Views and Vistas...... 20 Figure 11 Map showing adjacent developments ...... 21 Figure 12 Trays for sign-in and feedback ...... 21 Figure 13 Layout of displays ...... 22 Figure 14 KNP Vision Statement...... 22 Figure 15 Youth Forum Display ...... 22 Figure 16 Display of policies ...... 22
Table of tables
Table 1 List of Consultations Undertaken ...... 7
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1 Introduction
1.1 Introduction This Consultation Statement has been prepared to fulfil the legal obligations of the Neighbourhood Planning Regulations 2012. Section 15(2). Part 5 of the Regulations sets out what a Consultation Statement should contain: (a) Contains details of the persons and bodies who were consulted about the proposed neighbourhood development plan; (b) Explains how they were consulted; © Summarises the main issues and concerns raised by the persons consulted; (d) Describes how these issues and concerns have been considered and, where relevant, addressed in the proposed neighbourhood development plan.
1.2 Aims The aims of the Knebworth Neighbourhood Plan consultation process were: To involve as much of the community as possible throughout all consultation stages of Plan development so that the Plan was informed by the views of local people and other stakeholders from the start of the Neighbourhood Planning process; To ensure that consultation events took place at critical points in the process where decisions needed to be taken; To engage with as wide a range of people as possible, using a variety of approaches and communication and consultation techniques; and To ensure that results of consultation were fed back to local people and available to read (in both hard copy and via the Steering Group’s website) as soon as possible after the consultation events.
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2 List of Consultations undertaken
Table 1 List of Consultations Undertaken
Key Communication Point Format Date(s)
1 Announcement of proposal to Annual Parish Meeting May 2016 develop a Neighbourhood Plan
2 Initial survey – ballot box locations Individual Interview Nov 2016
3 Survey of households Direct mail to all households Jan 2017
4 Presentation of purpose of plan Parish meeting May 2017
5 Safer Neighbourhood Team Face to face meetings with Sep 2017 PCSOs
6 Scout & Guide Group Online, email, telephone and Oct 2017 face to face
7 Youth Project Online, email, telephone and Oct2017 face to face
8 Children Centre provision Online, email, telephone and Nov2017 face to face
9 Safety and Security – Online research Nov 2017 Neighbourhood Watch
10 Hertshelp service Face to face meeting Dec 2017
11 Adjacent Parish Newsletters Progress reports sent Dec 2017 to present
12 GP Practice Manager Regular face to face meetings Sep 2017 to present
13 Patient Participation Group Regular face to face meetings Sep 2017 to present
14 Community Library Committee Regular face to face meetings Sep 2017 to present
15 Knebworth Guide Group Regular face to face meetings Sep 2017 to present
16 Knebworth Football Club Chairman Email and occasional face to Sep 2017 to present face meetings
17 Great Ashby parking survey Face to Face residents Mar 2018
18 Housing Needs Survey Direct mail to all households Apri2018
19 Presentation of Vision and Public open days Apr 2018 objectives
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20 Presentation of Vision and Annual Parish Meeting May 2018 objectives
21 Sport & Leisure Survey e-mail survey Jun 2018
22 Schools Engagement Presentation and meeting Jun 2018
23 Business Survey Individual Interview Jul 2018
24 Councillor Lisa Nash surgery Public surgery Jul 2018
25 Councillor Steve Deakin-Davies Face to face meeting Jul 2018
26 Youth Focus Group Workshop Oct 2018
27 Parking Survey Observation of trends Oct 2018
28 Landowners’ Meeting Face to face meeting Nov 2018
29 Estate Agent survey Individual Interview Dec 2018
30 Landowners’ Meeting Face to face meeting Jan 2019
31 Presentation of policies Open Day Mar 2019
32 Presentation of progress Annual Parish Meeting May 2019
33 Regulation 14 consultation Direct mail to all households, Mar to May 2020 on-line and mail feedback
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3 Individual Consultations
3.1 Announcement of proposal for a Neighbourhood Plan – May 2016 During the Annual Parish Meeting it was announced that Knebworth Parish Council (KPC) intended to produce a Neighbourhood Plan and a request was made for volunteers to form a Steering Committee. 3.1.1 Outcomes: A number of individuals came forward and a Steering committee was formed with a member of the Parish Council as chair. Subsequently the chairman stood down and a volunteer took up the role of chairman.
3.2 Household Survey Preliminary work – November 2016 Discussions with shopkeepers, etc, for permission to place boxes on their premises for survey replies (face to face.) Explaining the NP process. Finding extra places to locate posters and survey forms in addition to those above (face to face.) Explaining the NP process. 10 Businesses visited 7 Locations for boxes identified 3 Additional locations identified to display posters and hold blank forms.
3.3 Household Survey - January 2017 2,000 survey forms issued plus an insert in the Parish News. 366 Responses. See Appendix A for survey form 3.3.1 Key issues identified from the results: 1. Traffic 2. Schools 3. Housing 4. Access to medical and public services 5. Parking 6. Restaurants and bars
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3.3.2 Action Taken: Working Groups set up to develop the key areas of concern: Group 1- Traffic, Transportation and Parking Group 2- Local Economy (including Retail Restaurants and Bars) Group 3 -Environment and Flooding Group 4 -Housing and Character Group 5 –Schools Group 6 -Well-being (to include Medical and Public Services)
3.4 Presentation at Annual Parish Meeting – May 2017 A presentation about the Neighbourhood Plan was made to the general public at the Annual parish Meeting. This covered: Purpose of a Neighbourhood Plan Aspirations of the Steering Committee Progress to date See Appendix B for text of presentation
3.5 Liaison with Hertfordshire Constabulary – September 2017 - District Safer Neighbourhood Team Face to face meetings with two PCSOs from the Hitchin Safer Neighbourhood Team. The team offered to visit Link Up lunch club a few times during the year for elderly people to discuss worries. The elderly are less likely to use the online crime reporting service and prefer to talk to someone direct. In addition the PCSOs stated that, when considering good housing design, the development in Great Ashby was a continual source of problems for them. They are called out to deal with neighbour parking disputes almost every evening as there weren't enough parking spaces provided within the development. This provided increased awareness of the need for good design and adequate parking provision.
3.6 Liaison with Scout & Guide Group – October 2017 Mix of online, email, telephone and face to face meetings and direct fact-finding contact with group leaders. Discovered problems and requirements for continued use of current premises, plus lack of volunteers to run group sessions. Potential increased demand might not be met.
3.7 Knebworth Youth Project (youth club) – October 2017 Mix of online, email, telephone and face to face meetings and direct fact-finding contact with group leaders. Discovered how provision is achieved currently and the need for continued input.
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Figure 1 Presentation to Youth Project Figure 2 Engagement exercise
3.8 Children Centre provision (Early Years 0-5) – November 2017 Online research, email and one-to-one meeting with the Children's Centre manager. Discovered how service provision would change due to reduced funding. GP Practice Manager alerted to potential reduced access but increased demand to health services. Library staff at the Community Library stepped in to provide story time service
3.9 Safety and Security - Neighbourhood Watch – September 2017 Undertook on-line research regarding safety and security Discovered that there is a lot of good information online regarding crime, crime reporting and security, but elderly people prefer to speak to someone direct. There is a Senior Watch service, but there doesn't seem to be any information about this in any community venue. Highlighted need for a central community information space.
3.10 Hertshelp service – December 2017 An organisation providing: Independent information and advice services in Hertfordshire. Online research on service provision. Face to face meeting in Stevenage. Hertshelp advised that Knebworth residents could use this service to obtain help and self refer to necessary health and social care schemes. The library has some of this information, but there is no central location to access help and advice in Knebworth.
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3.11 Adjacent Parish Newsletters – December 2016 to date Information pages on NP process and updates on current progress sent on a regular basis by email to: Knebworth Parish News Datchworth Parish Council Datchworth Parish Magazine Woolmer Green Parish Council Woolmer Green Village News Welwyn Parish Council St Paul's Warden Parish Council Codicote Parish Council Kimpton Parish Council Knebworth Parish News is circulated to about 700 local households and is delivered free to the GP Surgery and Knebworth Library. Woolmer Green Village News is delivered free of charge to around 200 households (population 661). Datchworth Village News can be bought locally (population 1,524) and is delivered free to the GP Surgery and Knebworth Library. Positive responses for regular contributions from Woolmer Green and Datchworth (both use local services). NP progress available regularly to quite a wide range of people.
3.12 Surgery Practice Manager – September 2017 to date The Surgery Practice Manager was a member of the Wellbeing sub-group and attended a number of meetings. Contributed positively to Wellbeing objectives and policies
3.13 Patient Participation Group – September 2017 to date Regular face-to-face meetings, 3 members of the PPG were members of the Wellbeing sub- group and regularly attended meetings. Contributed positively to Wellbeing objectives and policies.
3.14 Community Library Committee – September 2017 to date Regular face-to-face meetings, 1 member of the Community Library committee was a member of the Wellbeing sub-group and regularly attended meetings. Contributed positively to Wellbeing objectives and policies
3.15 Knebworth Guide Group – September 2017 to date The District Commissioner for the Knebworth Guide Group attended one meeting of the Wellbeing sub-group. Contributed positively to Wellbeing objectives and policies
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3.16 Chairman of Knebworth Football Club – September 2017 to date Occasional face-to-face meetings held. Contributed positively to Wellbeing objectives and policies
3.17 Great Ashby parking survey – March 2018 Great Ashby is a housing development on the outskirts of Stevenage around 5 miles from Knebworth. It has a reputation for minimal parking provision which has lead to traffic problems and neighbour disputes. We undertook a survey of households to establish their key issues to seek to avoid a repetition of those issues in Knebworth. 100 households surveyed using a face-to-face questionnaire. 76% had insufficient off-road parking 63% did not use their garage for car parking 68% rated ‘parking’ as their biggest concern with their property 92% were not happy with parking arrangements in the road A short video was produced to highlight the issues of narrow roads and problem parking. See Appendix C for Survey Questionnaire See Appendix D for graphical display of data obtained
3.18 Housing Needs Survey – April 2018 Survey delivered to all households in Knebworth. 85 households responded See Appendix E for Housing Needs Survey questionnaire See Appendix F for graphic representation of data
3.19 Public Open Days – 19th and 21st April 2018 Two Open Days were arranged, one on a weekday and the other on a Saturday to attract a wider demographic. The same material was also displayed at the Parish Meeting. 3.19.1 Publicity A notice was included in the Parish News Information relating to the Open Days was put on Facebook/Twitter 3.19.2 Posters Posters were put up around the village a few days before the event. A poster was displayed in the station the day before the event. Posters were created to display on the door of the Village Hall. Some shopkeepers commented that they were unaware of the NP is about.
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Figure 3 Open Day Poster Figure 4 Local newspaper article
Displays covered all working groups Visitors were asked to vote on various issues using coloured dots or to write comments on post-it notes. Feedback suggested that this approach was appreciated by visitors. The ‘Locality’ video “Understanding Neighbourhood Planning” was shown on a continuous loop. 87 people attended over the course of 3 events The local MP attended as did a journalist from the local paper. Two major land owners involved with the Local Plan attended
Figure 5 Example title strip for display
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Figure 6 Example of displays Figure 7 Visitors at the Open Day
There was better interest shown on the Saturday when the display was combined with another event, eg afternoon tea organised by a local ‘Save our Pub’ group.
3.19.3 Key issues raised: • Not worth downsizing due to even house prices • Quality of Secondary schools • Width of pedestrian footways under 2 No. railway bridges • Retail, e.g. lack of restaurants These were important issues to residents but cannot be directly influenced by the Neighbourhood Plan, however the Plan can highlight these issues and the Steering Committee will include these issues in an Action Plan and feed the results back to the relevant bodies.
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Figure 8 Members of the Steering Committee engaging with visitors. See Appendix G for examples of display material
3.20 Presentation at Annual Parish Meeting – May 2018 The displays from the Open Days were set up at the back of the room before the Annual Parish Meeting. They received a great deal of attention from those attending the meeting. Further ‘votes’ received on all topics.
3.21 Sport & Leisure Survey – June 2018 Survey sent to all of the sport and leisure organisations within the village listed in The Knebworth Directory. 24 organisations were contacted. Poor general response, but comprehensive response from the Knebworth Football Club highlighting the need for increased facilities in Knebworth to prevent travelling to Stevenage, etc, for sporting venues. Also request from PPG walking group for continued access to the Watton Road Recreational Grounds for their fortnightly health walks. See Appendix H For Sport and Leisure Survey form
3.22 Schools Engagement – 19th June 2018 A 90-minute meeting was arranged with the School Pupil Parliament. A number of students attended and engaged with the process.
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They were given an exercise to work through to: • Establish levels of understanding of planning issues and • Identify attitudes to development within the village and its impact on traffic, walking and cycling to school. The students showed an impressive level of understanding of the issues involved with development around the village and made some very useful suggestions, which have been taken forward by the team. See Appendix I for agenda of Pupil Parliament discussion.
3.23 Local Business Survey – July 2018 Face to face survey with business owners to establish their views on a number of issues including forthcoming developments and to identify their plans for the future. 45 Businesses surveyed in Knebworth High Street and Station Road (i.e. the main village centre.) 3.23.1 Main issues raised: • Parking( for employees and customers) • Improving traffic flow in the High Street • Retention of Pub and a decent restaurant facility were supported • Possible locations of additional parking were discussed. • The issue of lower business rates was not raised as a particular issue. • Additional housing may increase footfall, which was seen as positive. • A couple of businesses were already looking elsewhere for suitable premises.
See Appendix J for sample of survey form See Appendix K for graphical representation and summary of outputs
3.24 Local Councillor Surgery – 14th July 2018 NHDC Councillor Lisa Nash holds regular surgeries for her constituents. The Steering Committee arranged attendance at the July surgery to discuss the Neighbourhood Plan with attendees.
3.25 Meeting with local councillor – 17th July 2018 3 members of the Steering Committee met with NHDC council member Steve Deakin-Davies. We discussed synergies between his objectives as a local councillor and the aims of the Neighbourhood Plan. We also identified areas of overlap and agreed ways that we could work together without sending conflicting messages to the public or working at cross- purposes.
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3.26 Youth Focus Group - 18th October 2018 Face to face workshop with young people who live in Knebworth. 10 young people attended The attendees gave good, well-thought out responses to questions posed. See Appendix L for example of Young People’s Survey form
3.27 Knebworth Parking Survey – October 2018 Visual survey of parking trends in unrestricted on-street parking spaces in 10 streets around the area of Knebworth Railway Station. Observations were also made of the level of occupancy of the station car park and the adjacent (closed) Station Pub car park. Initially hourly observations were made from 06:00 to 23:00 but experience showed that four times during the day were sufficient to acquire meaningful data: 05:00, 11:00, 15:00 and 20:00. Data showed that all streets and car parks were between 75% and 100% occupancy throughout the day. This raised concerns over additional parking availability once the new developments have been built. See Appendix M for output from Knebworth Parking Survey
3.28 Meeting with main Landowners – 14th November 2018 The four main development sites around Knebworth are on land owned by two major local landowners. Three members of the Steering Committee and the chairman of Knebworth Parish Council met with both landowners to present the aims of the Neighbourhood Plan and to discuss their proposals. The meeting was also attended by a representative of Gladman Developments, the developer appointed by one of the landowners. The Steering Committee updated the landowners with progress to date on the Neighbourhood Plan and took the opportunity to update them on progress with the NHDC Local Plan. Both landowners stated that they are keen to apply good design standards to the developments on their land and wish to leave a positive legacy to the village. The meeting was very amicable and all parties considered it useful and constructive. All parties agreed to continue to communicate on an as-required basis, with a provisional date of February set for the next meeting.
3.29 Estate Agent survey – December 2018 A number of local Estate Agents were surveyed by face-to-face interview to establish: • The demand for the types of property in Knebworth Parish in the immediate past and the present • The types of property currently available and those of which there is currently a shortage There are 4 Estate Agents with offices in Knebworth and all were surveyed.
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The result from each agent was different, but overall the greatest demand was for: • Properties towards the lower end of the scale under £500,000. • Freehold properties • Houses (as opposed to flats or bungalows) • Properties with 3 bedrooms. See Appendix N for one example of the completed survey form.
3.30 Meeting with main Landowners – 31st January 2019 Two members of the Steering Committee met with one of the main landowners to update them with progress on the Neighbourhood Plan and to further discuss their proposals. They presented more detail about their intentions and outlined some interesting proposals not directly connected to the housing developments that could potentially be of benefit to the vibrancy of Knebworth. Once again both parties considered it useful and constructive. All parties agreed to continue to communicate on an as-required basis. It was agreed that the next meeting would probably be in around 2 months.
3.31 Meeting with main Landowners – 1st March 2019 A further meeting was held with both main landowners. A proposal was made that any ‘Planning gain’ should be retained within Knebworth rather than diluted into NHDC funds for the whole district. The use of such monies should be determined by the view of Knebworth residents. This proposal was strongly supported by all parties. It was suggested that a charity may need to be set up for the purpose.
3.32 Public Open Day – 2nd March 2019 The purpose of the Open Day was to show local people the policies produced and get feedback in advance of the Statutory Consultation. 3.32.1 Publicity Posters advertising the event were displayed around the parish An invitation was published in the Parish Magazine A press release was sent to the ‘Comet’ newspaper and local radio station ‘BOB FM.’ 3.32.2 Format Vision, Objectives and Policies were displayed in full on poster boards. Particular reference was made to local green spaces, recreational green spaces, assets of community value and views. Attendees were asked to comment specifically on the importance of green spaces, recreational green spaces, assets of community value and views.
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Figure 9 Display of policies Figure 10 Map showing Views and Vistas
A 5-minute presentation was run every hour that explained: • The background to the Local Plan • Impact of the Local Plan • The purpose of the Neighbourhood Plan • Relationship of Local Plan to Neighbourhood Plan • The effect the Neighbourhood Plan can have on the Local Plan • The background to the KNP Steering Committee • An overview of our aims and objectives • The methodology used and consultations held to develop the plan to its current state • The next steps in having the Neighbourhood Plan adopted • Why we were holding the Open Day • What we wanted attendees to do • Thanked people for attending and participating
There was a copy of the Local Plan with tracked main modifications, for reference if required.
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Maps were used to show developments in other areas around Knebworth to demonstrate the potential impact on amenities in the village of adjacent developments. Two A3 copies of the masterplanning report produced by AECOM were made available for reference. Sheets were provided for attendees to record their name and an optional email or postal address.Attendees were issued with feedback forms and tables, chairs and pens were provided to enable people to complete them. Volunteers encouraged people to complete the feedback forms Figure 11 Map showing adjacent immediately, though some did opt to take developments them away to complete at their leisure.
3.32.3 Outcomes 175 people attended the Open Day. 69 completed feedback forms were received All policies received general support, but some opposition was noted in individual comments. Several comments indicated that some residents are still confused regarding the difference between Neighbourhood Plan and Local Plan, hence several objections were Figure 12 Trays for sign-in and actually about the Local Plan. feedback
Many comments were outside the scope of the Neighbourhood Plan. This demonstrated need for an Action Plan to support the Neighbourhood Plan.
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Figure 13 Layout of displays Figure 14 KNP Vision Statement
There were quite a few comments about things outside the scope of an Action Plan that the Neighbourhood Plan can do nothing about, e.g.: • The nature of businesses occupying retail/commercial premises. For example several people wanted ‘more restaurants’ • The frequency of trains or buses.
Figure 15 Youth Forum Figure 16 Display of policies Display
Two fulsome sets of comments were received: 10 pages from a professional planner and three pages from the NHDC Traffic engineer. The Open Day was considered to be a success and identified a general level of positive support for the policies that the team have developed. See Appendix O for analysis of Consultation responses from Open Day visitors.
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3.33 Presentation at Annual Parish Meeting – 1st May 2019 The Steering Committee Chairman and Vice-Chairman both made a presentation at the Annual Parish Meeting about the Neighbourhood Plan. The Chairman described the process so far to create the policies and explained the level of consultation that had been involved. The Vice Chairman reported back on the feedback received at the recent Open Day and reinforced the relationship between the Knebworth Neighbourhood Plan and the North Herts District Council Local Plan. Questions were then taken from the floor.
3.34 Meeting with NHDC Senior Planning Officer – 29th May 2019 Face to face meeting with Clare Skeels, Senior Planning Officer for North Herts District Council to review draft policies to identify any areas that may not be considered acceptable by the inspector. Generally the policies were considered to be of an acceptable standard, but a number of relatively minor issues were identified: 1. Housing numbers – a Neighbourhood Plan cannot mandate numbers of homes on any particular site but can propose a housing density. 2. School provision – Some review of the wording regarding school provision in sites KB3 and KB4 was suggested as it is currently slightly ambiguous. 3. Assets of Community Value – Some conflict between Planning Regulations and ACV legislation. Knebworth Parish Council needs to agree each asset that is proposed for ACV status. 4. Non-design Heritage Assets – The text needs to explain that Knebworth has a local list of Heritage Assets and that those listed in the Neighbourhood Plan are additional to that list. 5. Referenced Code for Sustainable Homes – The code referenced in the text is not an approved document. Suggested to source a relevant paper from the Building Research Establishment. 6. KBW1 Supported Development – The text needs to be more specific as to what type of development will be supported, i.e. Commercial or Residential. 7. Section 106 – The text needs to state that the list of projects in the Action Plan will be reviewed regularly – suggested once or twice per year. 8. Habitats Regulation Form – This has been updated since the Local Plan was drafted. Clare Skeels agreed to forward an updated form for our use. Clare Skeels also updated the team on current progress with the Local Plan.
3.35 Review of Consultation Statement – 10th July 2019 The Parish Council reviewed the Consultation Strategy and the Consultation Statement at a regular Parish Council Meeting. Both documents were accepted without comment.
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3.36 Regulation 14 Consultation – March to May 2020 The Parish Council reviewed the Consultation Strategy and the Consultation Statement at a regular Parish Council Meeting. Both documents were accepted without comment. 3.36.1 Background The date for the Regulation 14 Consultation was agreed as part of a programme finalised by the Steering Committee on 20th February 2020 and the period for the consultation was set as 21st March to 9th May 2020. The consultation period was extended beyond the standard 6 weeks to take account of 2 bank holidays in May. The consultation strategy included a summary document that outlined the vision and objectives of the Plan and listed all the policies from the Plan, which would be delivered to every household between 14th and 21st March and an ‘open day’ on 18th April, where residents would have the opportunity to meet the Steering Committee and ask questions. 3.36.2 Delivery The summary document was printed in February 2020 and was delivered during the first two weeks of March, just before Prime Minister Boris Johnson declared the Covid-19 lockdown measures. The Steering committee discussed the parameters of the lockdown and agreed that, as many of the Steering committee members were in the government’s ‘vulnerable’ category, an open day was not possible under the conditions of the lockdown. The Steering Committee convened an ‘on-line’ meeting using a video conferencing platform to discuss contingency plans to ensure that the Regulation 14 consultation could still be undertaken. A number of actions were agreed at that meeting to facilitate a meaningful exposure of the Plan to residents and to enable responses from all sectors of the community, including those who did not have access to the internet or e-mail. On-line access to the Plan would be enhanced by: • Splitting the plan into its constituent parts and uploading all sections to the Knebworth Neighbourhood Plan website • Clearly signposting the Plan sections on the website landing page Awareness of the consultation process would be increased by placing information about the Plan and ways of responding in various locations and on different platforms: • Various Facebook pages relevant to the parish • Articles in the parish magazine • Posters in prominent positions around the parish, particularly in shops where people would go as part of their essential journeys and on the door of the Village Hall • Local WhatsApp groups that Steering Committee members belonged to The closing date for the consultation was extended from 9th May to 30th May to give people extra time to respond. The extended consultation period also encompassed the possibility at that time that the pandemic might have passed and lockdown might be eased by the end of May. In the event, that did not happen.
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3.36.3 Responses Once the consultation period had closed all the comments that had been received were collated onto a spreadsheet for review by the Steering Committee and the various sub- groups. There were: • 329 Comments from residents • 90 Comments from statutory bodies. Despite the challenges presented by the Covid-19 lockdown measures this was considered an encouraging number of responses from the residents of the parish. A full spreadsheet of responses is available on the Knebworth Neighbourhood Plan website: https://knebworthneighbourhoodplan.org.uk/ All those responses resulting in a change to the Neighbourhood Plan, i.e. a policy, a paragraph or an Appendix, map or other part of the Plan are attached to this statement at Appendix P . 3.36.4 Analysis of Responses All responses were considered. 3.36.4.1 Responses from Statutory Bodies A total of 90 comments were received from 6 statutory consultees. 7 comments resulted in changes to policies and a total of 5 policies were changed. 10 comments resulted in a change to wording, including a number of simple typing errors, without a material change to policies. 3.36.4.2 Non-Statutory Responses Comments were received from 26 residents and from one of the two major landowners of the sites in the Local Plan and their developer. The committee approached the other major landowner to absolutely ensure that he was aware of the consultation process and encouraged him to comment. He made a general statement in support of the Knebworth Neighbourhood Plan but otherwise declined to make specific comments. There were a total of 329 comments received from non-statutory consultees. 34 of the comments were relevant to the NHDC Local Plan rather than the Knebworth Neighbourhood Plan and related to concern over the ability of local infrastructure to cope with additional developments, particularly to increases in traffic levels. The Steering Committee have taken every opportunity to stress the differences between NHDC Local Plan and the Knebworth Neighbourhood Plan in all publicity material relevant to Regulation 14. We believe that these comments have arisen because some people still do not understand this, but also because they see it as their only opportunity to make their voice heard. There were a small number of comments that related to the Vision or the Objectives of the Knebworth Neighbourhood Plan, but the Steering Committee agreed that changes should NOT be made to these elements of the Plan. The Vision and the Objectives were agreed by the Steering Committee based on the results of a survey of parish residents undertaken at the start of the process and they underpin the whole Knebworth Neighbourhood Plan. Consequently any change could potentially invalidate some of the policies within the Plan.
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3.36.5 Statistics • 26 Residents responded • 1 landowner responded • 1 Developer responded • 6 Statutory Bodies responded • 419 Comments received in total • 34 Comments related to NHDCLP, not KNP • 26 Comments resulted in changes to the preamble and Introduction • 153 Comments resulted in policies being updated • 29 Policies were updated • 3 Comments resulted in visual media being changed (Photographs or maps) • 14 Comments resulted in correction of minor typographical errors • 16 Comments referred to existing Action Plan items • 8 Comments resulted in new draft Action Plan items
3.37 Action Plan During the course of developing the Neighbourhood Plan a number of issues have been raised which fall outside the scope of the Neighbourhood Plan but which were clearly of importance to the people of the parish and of potential benefit to the parish. These had all been collected into an Action Plan. 16 of the Non-statutory responses related to items that were already in the Action Plan and 8 resulted in additional items being added to the Action Plan. See Appendix Q for a copy of the Action Plan dated 27th September 2020
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Appendix A Household Survey
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Appendix B Text of Parish Meeting Presentation
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Appendix C Great Ashby Parking Survey
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Appendix D Great Ashby Parking Survey Data
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Appendix E Housing Needs Survey
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Appendix F Housing Needs Survey data
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Appendix G Example of Open Day displays
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Appendix H Sport and Leisure Survey
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Appendix I Agenda for Pupil Parliament Exercise
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Appendix J Local Business Survey
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Appendix K Business Survey Graphs and Summary
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Summary of all four Average Demand Demand Average Demand Demand Average Shortfall Shortfall sources Demand Minimum Maximum Demand Minimum Maximum Shortfall Minimum Maximum (Last Year) (Last Year) (Last Year) (Current) (Current) (Current) (Current) (Current) (Current)
Value of Property < £250k 20% 0% 55% 21% 0% 55% 11% 0% 15%
£250k - 300k 16% 10% 20% 19% 15% 20% 31% 10% 65%
£350k - 500k 24% 15% 35% 26% 15% 35% 45% 10% 80%
£500k - 750k 26% 5% 45% 21% 5% 40% 9% 5% 10%
£750k - £1m 11% 5% 20% 10% 5% 20% 4% 0% 10%
£1m - 1.5m 3% 0% 5% 3% 0% 5% 0% 0% 0%
£1.5m - 2m 0% 0% 0% 0% 0% 0% 0% 0% 0%
> £2m 0% 0% 0% 0% 0% 0% 0% 0% 0%
Style of Property Freehold 91% 80% 100% 94% 90% 100% 90% 80% 100%
Leasehold 9% 0% 20% 6% 0% 10% 10% 0% 20%
Number of Bedrooms 1 9% 0% 20% 11% 0% 20% 13% 0% 20%
2 24% 15% 40% 25% 20% 40% 20% 0% 30%
3 41% 30% 50% 38% 30% 50% 41% 30% 50%
4 14% 5% 20% 16% 5% 30% 21% 5% 50%
5+ 13% 5% 20% 10% 5% 20% 5% 0% 10%
Type of Property House 78% 65% 85% 76% 60% 85% 60% 35% 90%
Bungalow 9% 2% 20% 9% 2% 20% 33% 10% 60%
Flat 13% 5% 18% 15% 5% 20% 8% 0% 15%
Type of Occupancy Owner Occupied 91% 80% 100% 94% 90% 100% 96% 95% 100%
Buy to Let 9% 0% 20% 6% 0% 10% 4% 0% 5%
= largest value in each major category Averages from four Knebworth estate agents
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Appendix L Young People’s Survey
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Appendix M Knebworth Parking Survey Output
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Appendix N Estate Agent Survey
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Appendix O Feedback from Open Day
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Appendix P Responses from Regulation 14 Consultation resulting in an amendment
Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBLE1 New 5.2 21 The policy states that new businesses will be Map Policies Map includes 'Retail' and 'Non- NHDC Businesses supported in existing employment locations within change retail Commercial' areas. . the existing built-up area. However, it is unclear where those existing employment locations are in the village as they have not been defined on the accompanying policies map. Are the existing employment locations confined to the “High Street”? The neighbourhood plan could be made clearer if the employment locations are better defined.
KBEF5 Views and 9.6 64 There is no survey and analysis to show the location Action Green Infrastructure Audit has been HCC Character of existing important local natural and built Plan added as a project to the longer Action Areas features, GI assets, and routes, or opportunities for change Plan. where these aspects could be improved. The community’s aspirations and opportunities for proposed enhancements should be identified and mapped wherever possible so that they can be evidenced and secured through forthcoming developer contributions.
Tools to guide communities in surveying and analysing their local natural and built environment include GI Audits and Placecheck.
Append Appendix E 99 Strategic Policies – the definition seems to end mid- Glossary Item completed in Glossary KNP23 ix sentence Change
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBBE4 Design 6.5 30 The design of the new developments should also Policy Policy KBT1 covers this. KNP13 take into account the need to adapt the existing KBT1 infrastructure and access ways to/through/within change the village. Linking another 200+ housing developments to the same 1 way road is not feasible. Knebworth already had significant challenges with the number of cars parked on the side of the roads (with garages unused, or because of families buying houses with 1 parking space but owning multiple vehicles) that only allow 1 way traffic. If further developments are desired, then the road system and supporting infrastructure needs developed first, giving confidence to the local community that the development is sustainable. Catering for parking spaces for new houses, and ensuring they have proper access only will amplifies the problems in other areas of Knebworth. Also, I am confident that such considerations have been taken into account when latest developments were approved – such as Wadnall Way and Woodstock, yet the parking and access situation in these 2 areas is appalling. You can barely drive to your property because of the high number of cars parked each side of the road every night.
Gen General 1 1 Aecom Report – The Aecom report is a useful body Policy The AECOM Report has been removed KNP03 Comments of information. It is stated throughout the change from the KNP, but section 3.1 Design individual KNP policies that they should comply Guide has been included in KNP as an with the Aecom report and therefore the Aecom Appendix. report – which I don’t believe has been subject to public consultation and revision – would become a The status of the AECOM report has been statutory part of the KNP. That point is repeated in clarified in the Introduction, including an
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. KNP para 6.6. Unfortunately, reading the Aecom emphasis that any layout plans and site report, it is clear that its authors only intended it as access descriptions were purely high level preliminary guidance and expected that illustrative. others (the housebuilder and/or statutory consultees like Herts Highway presumably) would use independent site-specific data to actually determine how sites would be designed and built. So, for example, the Aecom report states (for KB4) on page 44 that “the advice set out in this note is preliminary in nature and will need to be confirmed by more accurate assessments based on a topographical survey”. Several areas of the Aecom report are therefore based only on desk-top assessments or Google Aerial View rather than actual and detailed site surveys. Drafting the KNP in a format whereby its policies are formally reliant on those preliminary Aecom opinions (rather than comprehensive site surveys) will create artificial obstacles to the implementation of developments. I doubt that was the intended goal and so it would be better to describe the Aecom report as being a source of supportive information rather than “hard wiring” policies to its findings. There are many examples of conflicts created by this direct inclusion of the Aecom report into KNP policies and I have not listed them all below, but you might want to refer to KBBE4 and KBBE5 below for examples.
KBDS01 Retention of 4.2 19 KBDS01 (Strategic gaps) – The requirement for Policy KBSD01 clarified. KNP03 Separation these gaps as currently worded doesn’t actually change Between permit KB4 (or KB1 or KB2) to be built. A simple Settlements change in wording within the policy to reference these sites would achieve your goals of protecting
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. Knebworth from sprawl and coalescence but without conflicting with the NHDC LP.
KBDS01 Retention of 4.2 19 This Policy is fundamental to retaining the Policy KBSD01 clarified. KNP14 Separation character and scale of the village. It needs clarifying change Policy KBDS01 refers to the Green Belt Between [to reflect the commitment in the NHDCLP to the boundary, as re-defined by the NHDCLP, Settlements future development of site KB4, which in itself NOT the boundary as current. contradicts the proposed Policy by narrowing the gap between Knebworth and Bragbury End] and strengthening. The final clause should perhaps read : "....between Knebworth [as extended by Site KB4] and Bragbury End will be unacceptable."
KBDS01 Retention of 4.2 19 5.2.2. A priority of the KNP is to retain existing Policy KBSD01 clarified. KNP15 Separation separation between the settlements which make up change Policy KBDS01 refers to the Green Belt Between the KNP plan area and to neighbouring towns and boundary, as re-defined by the NHDCLP, Settlements villages. Whilst Gladman acknowledges this NOT the boundary as current. objective, we would suggest that the policy could be strengthened by providing additional evidence that clarifies why these gaps are important. 5.2.3 Notwithstanding this, Gladman does have some concerns with the policy wording as drafted. However, before considering these, Gladman would note that the land referred to in the policy currently falls within the designated Green Belt wherein the NPPF makes clear that the fundamental aim of Green Belt policy is to prevent urban sprawl by keeping land permanently open. 5.2.4 In accordance with paragraphs 135, 136 and 137 of the NPPF, the extent of the Green Belt is already established, and changes to Green Belt
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. boundaries should only be altered in exceptional circumstances when evidenced and justified through the preparation of updating of Plans. In North Hertfordshire, proposed revisions to Green Belt boundaries are currently being considered as part of the Local Plan examination and have resulted in the removal of some land around Knebworth to provide strategic allocations. If the NHLP is found sound, Green Belt boundaries will once again be set with any land beyond the revised boundaries being subject to stricter controls over development, which inevitably will mean the land remaining permanently open. 5.2.5 However, should the Parish Council consider that KBDS01 is needed, Gladman believes it would be necessary to make some revisions to the Policy to meet the Basic Conditions. In the first instance, the KNP policy states that any new development within settlement gaps will be resisted. However, as site KB4 is located within the gap that exists to the east of Knebworth to Bragbury End, the drafting creates a tension the strategic allocation of this site in the NHLP. To remove this tension, Gladman suggests that the policy is revised to acknowledge the proposed allocations in Knebworth and confirm that these are excluded from its scope.
KBDS01 Retention of 4.2 19 5.2.6 Secondly, the policy is not currently supported Policy The Policies Map does include the KNP15 Separation by a Policies Map that confirms the land areas that Change original village settlement boundary and Between are protected by the gap, and there is only limited the NHDCLP sites (which are proposed Settlements description provided to inform applicants and the by NHDCLP to betaken out of green belt). decision maker as to which land could be subject to All land outside the settlement boundary
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. the policy’s requirements. To meet guidance in the PLUS the proposed development areas is PPG on policies being clear, unambiguous, and green belt, and is the green belt referred consistent with PPG(PPG Paragraph 041 Ref ID: 41- to in Policy KBSD01. 041-20140306), the Policies Map should be revised to define where in the plan area KBDS01 is applicable to.
KBDS01 Retention of 4.2 19 Thirdly, the policy aims to impose an absolute Policy KBSD01 reworded. KNP15 Separation restriction on new development, which Gladman Change Between considers may go beyond advice in the NPPF on Settlements Green Belts, which identifies certain prescribed types of development that are not regarded as inappropriate (see 2019 NPPF Paragraph 145). As it may also be the case that development could take place within the gaps without impacting on openness or the perception of promoting coalescence, Gladman would suggest amending the policy to refer to the types of development that are not regarded as inappropriate in the Green Belt.
KBDS01 Retention of 4.2 19 6.2.1 KBDS01: Define areas of these gaps and Policy KBSD01 clarified. KNP15 Separation clarify that KB1, KB2 and KB4 are excluded in line Change Policy KBDS01 refers to the Green Belt Between with their expected delivery in the NHLP. Amend boundary, as re-defined by the NHDCLP, Settlements policy requirement to reflect permitted exceptions NOT the boundary as current. in the Green Belt as cited in Paragraph 145 of the 2019 NPPF. Confirm that developments that do not alter the openness of the gap or perception of its closing will be acceptable subject to other policies/material considerations.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBDS01 Retention of 4.2 19 To the east of Knebworth, this is contradicted by Policy KBSD01 clarified. KNP24 Separation KB4 change Policy KBDS01 refers to the Green Belt Between boundary, as re-defined by the NHDCLP, Settlements NOT the boundary as current.
KBDS01 Retention of 4.2 19 The areas described in the policy are all within the NHDC have proposed, in their Local Plan, NHDC Separation green belt. There is clear policy guidance in the to alter the boundary of Green Belt Between National Planning Policy Framework, policies in the around Knebworth village, to un-protect Settlements saved local plan and in the emerging local plan areas, thus allowing development. Owing which would provide the framework within which a to the strength of feeling on this issue development proposal could be determined. It is Policy within the village, it is felt necessary to considered that this policy is not needed in the Change remind all concerned that the KNP is neighbourhood plan. representing the feeling of the community, and that any further attempts at moving the Green Belt boundary (beyond those proposed by the NHDCLP) will be resisted.
KBDS02 Density of 4.3 19 Consider changing policy to read ‘…inappropriately Policy Policy KBSD02 reworded. KNP07 Housing high or low density….’ Higher density housing may change Development be more appropriate in some locations and may help reduce the ‘sprawl’ of urban development onto greenfield sites. Low density is not always best. Good design can help create high quality, higher density housing yet still retain an open/green character. This is particularly important when it comes to designing good quality affordable housing.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBDS02 Density of 4.3 20 KBDS02 (Density) – The Aecom report mentions Policy Policy KBSD02 reworded. KNP03 Housing assumed densities for particular sites based on its change Development own illustrative masterplans (- see later on the masterplan topic). However Aecom’s report states that the actual density should be based on more detailed site-specific criteria. This is one example of the point I make above under the “Aecom report” heading. I think the KNP has inadvertently gone beyond Aecom’s conclusion and it would be better not to “hardwire” densities into KNP policies based simply on the preliminary Aecom report.
KBDS02 Density of 4.3 20 Policy KBDS02 seeks to refer applicants to design Policy Policy KBSD02 reworded. KNP15 Housing guidance including the Knebworth Neighbourhood change Development Masterplanning and Design Guidance prepared by AECOM. On reviewing the AECOM report, we note that this typically only provides a high-level review of density and in doing so, also acknowledges that there may be a need to adopt a variety of densities that may need to be adjusted within a sites and their respective parcels (including in relation to the development of KB4). As such, Gladman would suggest that the priority for the policy should be to ensure that sites are developed having regard to local character, which is normally arrived at considering site constraints and opportunities. For this reason, Gladman would suggest that the Policy and accompanying design should not seek to impose any overall set density limits, as this is better informed by site-specific evidence borne out at the application stage, through the design iteration process.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBDS02 Density of 4.3 20 6.2.1. KBDS02: Revise policy to outline that density Policy Policy KBSD02 reworded. KNP15 Housing will be arrived at on a site-specific basis considering Change Development site opportunities and constraints, good design practices, and local character.
KBDS02 Density of 4.3 20 Density of Housing Development Policy HMOs included in 6.1 and in Glossary. KNP20 Housing HMOs represent an increase in dwellings per change Development hectare (DPH) and there is already an application to convert one single dwelling to a HMO for 10 bedrooms on a conservation area. If this were to be repeated it would not only represent an increase in DPH but also impact on parking, traffic, and hence road safety.
KBDS02 Density of 4.3 20 Policy KBDS02 Density of Housing Development Policy KBSD02 reworded. CPRE Housing The CPRE (in partnership with others) published a Development recent National Housing Design Audit that highlighted poor rural design and in part a problem with numerical approaches to low density. Design review and design coding proved the best means to deliver better quality. The Living with Beauty Policy report advocates a tighter ground floorplan; change proportionally smaller units may generate greater village character (eg 50dph) than a standard ‘low density’ pattern of detached suburban housing (30dph). Low density is not a determinant of good design and can frustrate it. Better use of density can also reduce the land take of sites and loss of valuable countryside.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBLE2 Rural 5.3 22 Section 5.3 KBLE2 now contains reference to HCC Businesses Policy KBLE2 Rural Businesses should include a 'demonstrated to have a minimal traffic reference to not generating a traffic impact. This is impact' included as part of KBLE1 New Businesses. Policy Accessibility to such sites should also be a change consideration as some rural locations may not be sufficiently served by more sustainable mode options.
KBLE3 Village Centre 5.4 23 The District Council supports the principle of KBLE3 reworded NHDC and Existing retaining the diverse range of services in the village Any development for retail use would be Businesses centre. As the policy is currently worded, it feels acceptable in the retail area, with offices negative in its approach, should the policy be Policy or residential above. Commercial amended to take a more positive approach and set Change services will be acceptable in the Non- out what types of development within the retail retail and commercial areas. area would be encouraged? There are a number of It is believed that a NP cannot go to more specific comments about this policy: specific levels.
KBLE3 Village Centre 5.4 23 A new sentence could be added to the policy which KBLE3 reworded NHDC and Existing simply sets out the extent of the Retail Area: Policy Businesses “The retail area on London Road and Station Road Change are defined on the policies map.”
KBLE4 Community 5.5 24 Ensure that Multiple occupancy (office) Business Policy Policy KBLE4 Reworded KNP19 Businesses centres are clearly included change
KBLE4 Community 5.5 24 Policy KBLE4 Community businesses and KBLE5 Policy KBLE4 Reworded CPRE Businesses Home working The supportive policies are noted. The quality of Policy places can be enriched by mix of uses, so this is change supported if buildings are planned to be flexible with future adaptability for a range of uses designed into them. Economics may mean there
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. may be an initial period when residential use is the only viable option.
KBLE4 Community 5.5 24 The supporting text for the policy is positive in its Policy KBLE4 Reworded NHDC Businesses support for the provision of premises for business uses, but the policy states that these types of proposal are “more likely to be supported”. There are no requirements in the emerging Local Plan for Policy the proposed site allocations in Knebworth to change include buildings or premises for businesses. If the neighbourhood plan wants to encourage this type of provision, the policy should be more positively worded?
KBLE6 Telecommuni 5.7 25 5.2.10 Gladman suggests that the policy, as drafted, Policy Policy KBLE6 Reworded KNP15 cations requires some revision to acknowledge that the change delivery of telecommunications infrastructure is by statutory providers such as Openreach, rather than developers themselves. The policy may also act as an unnecessary burden on small or minor development as it does not seek to differentiate between the scale of development that would be required to provide telecommunications infrastructure. 5.2.11 If the Parish Council intends that the Policy KBLE6 should apply to only new major development, such as the strategic allocations in Knebworth, Gladman would suggest making this clear in its wording. Gladman would also suggest that the focus of the policy should be to facilitate the delivery of telecommunication infrastructure,
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. which would then enable this to be installed by the statutory provider.
KBLE6 Telecommuni 5.7 25 6.2.1. KBLE6: Revise to set out the need for major Policy Policy KBLE6 Reworded KNP15 cations development proposals to ensure sufficient scope change for the installation of telecommunications equipment by statutory providers.
KBBE1 Housing Mix 6.2 26 As somebody who is registered on the NHDC self- Policy This issue is mentioned in the text of KNP22 build register it is particularly disappointing that, Change KBBE1 and KBBE2, but there is no across 3 separate sites and 736 homes, there is not mention of the need to provide this in the even one site that is to be dedicated to self builders. NHDCLP. The allocation of land for this This is even more surprising given the government purpose would need to be negociated recommendation that this should feed into the with the landowner/developer. Strategic Housing Market Assessment and would urge there to be a rethink on the glaring omission of any self build provision in Knebworth.
KBBE1 6.1 26 Policies - Built Environment - Introduction Policy HMO effect on parking is referred to in KNP20 Intro Paragraph 4 refers to parking problems in Great change 6.1 Built Environment - Introduction Para Ashby that it would not like to be seen in 4 Knebworth but no mention is made alongside the problems of garage usage of the problem exacerbated by the many HMOs in the area.
KBBE1 Housing Mix 6.2 28 24 Dec 2019 Intergenerational housing Policy Reference to downsizing included in text KNP23 We do have some local evidence for this one: A change under Policy KBBE1 desire to downsize, thwarted by costs - as presented by residents at the Open day. I just heard a documentary on 'Inter-generational housing'. It mentions the housing shortage, but also 7 million under-occupied properties. Also a 'Better ageing fund'.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBBE2 Sustainable 6.3 28 KBBE2 (Efficiency) – We share your interest in Policy Policy KBBE2 uses the term '...should be KNP03 Buildings incorporating green initiatives into the site. One change designed to be at or near Zero carbon look at our own farm website will show you that we wherever possible.' This does not conflict positively put environmental initiatives into with NHDCLP Policy SP9 - Design and practise on the farm and at our own expense. We Sustainability, or the text accompanying are aiming to also do so with KB4. In terms of Policy D1 - Sustainable Design, which energy efficiency, I am sure by virtue of our design states - 'Development should meet the goals and by where technology and legislation requirements of the most up to date stands today, KB4 will provide more highly efficient standards on carbon emissions and homes than Knebworth has ever seen on this scale embedded renewable sources. The before. In the long term, I believe UK housing reduction of carbon emissions should be estates might even be routinely deliverable on the achieved by both making new “zero carbon” basis required under the KNP policy. development as energy efficient as However, that zero-carbon basis goes well beyond possible and through increasing the the NHDC LP and is an aspirational rather than amount of energy gained from renewable commercially deliverable aim for a development of sources.' this type and location at the moment and is unlikely to infact result in the site achieving NHDC’s aims of being commercially brought forward. I would encourage you to review how this policy is drafted.
KBBE2 Sustainable 6.3 28 6.2.1. KBBE2: Revise to encourage high energy Policy This is already covered by NHDCLP HS3 KNP15 Buildings efficiency in developments and lend support to change and SP9 carbon neutral schemes.
KBBE2 Sustainable 6.3 28 Siting and orientation of buildings to optimise solar Policy KBBE2 amended to include: KNP19 Buildings gain will be supported where the resultant built Change 'Energy usage should be designed to be form respects the character of the setting at or near Zero carbon wherever possible utilising simple design solutions such as orientation of buildings to optimise solar gain.'
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBBE2 Sustainable 6.3 28 Whilst we support the principle of encouraging Policy re-worded to make this an 'ask' NHDC Buildings sustainable construction methods for new rather than a requirement. development the 1st sentence of the 2nd paragraph of the policy should be deleted, and the policy wording re-considered. In March 2015 the government published the optional technical housing standards for new housing which rationalised the different standards into a more streamlined system and withdrew the Code for Sustainable Homes. The accompanying Written Ministerial Statement states: "local planning authorities and qualifying bodies preparing neighbourhood plans should not set in their emerging Local Plans, neighbourhood plans, or Policy supplementary planning documents, any additional Change local technical standards or requirements relating to the construction, internal layout or performance of new dwellings. This includes any policy requiring any level of the Code for Sustainable Homes to be achieved by new development; the government has now withdrawn the code, aside from the management of legacy cases." Whilst the relevant amendments have not been enacted to date, the recent consultation document, Future Homes Standard includes options on whether to commence those amendments. If enacted this would stop any measures being set through planning policies.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBBE4 Design 6.5 30 5.2.18 The AECOM Report is not subject to the same Policy The AECOM Report has been removed KNP15 degree of scrutiny and consultation as the KNP. It change from the KNP, but section 3.1 Design has not been prepared by a qualifying body for Guide has been included in KNP as an Neighbourhood Plan preparation. It has not and will Appendix. not be examined for its compliance with the Basic Conditions. For these reasons, the AECOM Report is The status of the AECOM report has been not capable of forming part of the statutory clarified in the Introduction, including an development plan. Instead, its consideration could emphasis that any layout plans and site only be limited to an evidence base document that access descriptions were purely could be used to inform the policies of the KNP, and illustrative. act as a material consideration in the decision- making process. To prevent any conflict with the Basic Conditions, we would suggest that reference to the AECOM report as forming a statutory part of the KNP should be removed. 5.2.19 In terms of other aspects of Policy KBBE4 Gladman has no objection to the summary design guidelines that are set out in the policy.
KBBE4 Design 6.5 30 KBBE4 (Design) and KBBE5 (Masterplanning) – Policy The AECOM Report has been removed KNP03 As I have outlined above, we have put an inordinate change from the KNP, but section 3.1 Design amount of effort into attempting to design KB4 for Guide has been included in KNP as an modern homes and in a way which also Appendix. acknowledges Knebworth’s garden village heritage and which provides for green spaces and creates an The status of the AECOM report has been attractive additional community within Knebworth. clarified in the Introduction, including an We are conducting numerous detailed site studies emphasis that any layout plans and site covering ecology, arboriculture, archeology, noise, access descriptions were purely air quality, drainage, highways, topography, ground illustrative. condition, heritage etc etc. We are also working directly with NHDC, with Herts Highways, Thames The reference to a reserved area of Water and other statutory bodies. All of this data – and our overarching design goals – helps to inform
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. our site layout, masterplanning and design. “Ancient Woodland” behind Haygarth However, this contrasts significantly with the scope has been removed and aim of Aecoms work. The Aecom report’s authors supplied an illustrative masterplan and other design/site features in their report, but went on to state that their information was only generic and needed to be replaced with site-specific findings. Unfortunately, by incorporating (for example) the Aecom masterplan into the KNP policy, it becomes a restriction on proper design. I don’t believe that was Aecom’s intended outcome. By way of a small example, the Aecom masterplan for KB4 includes a reserved area of “Ancient Woodland” behind Haygarth which the KNP policy therefore requires to be preserved undeveloped. Aecom describe this “woodland” as dating back to at least the year 1600. That is simply not correct – as any site visit would reveal. There are two mature oak trees on the inner periphery of that area, which we would absolutely intend to preserve, but the “ancient woodland” shown on their masterplan is just the spoil heap from groundworks at the Knebworth Primary school which was dumped on our arable field when the school playing field was extended in the 1970’s and has since become overgrown with brambles. It’s this type of unintended consequence that can cause the KNP policies to act as an impediment to achieving the policies of the NHDC LP. If policies in the KNP do act against implementation of the NHDC LP sites, then the Inspector will conclude that they breach the Basic Conditions and the KNP cannot be therefore approved.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBBE4 Design 6.5 30 Could this include consideration of charging points Policy Policy addition - Provision for Charging KNP07 for electric vehicles, both private and communal? change for Electric vehicles specified.
KBBE4 Design 6.5 30 The first clause in the last paragraph of the Policy is Policy Policy re-worded. KNP14 a comment, not a policy, is of questionable veracity change and should be deleted, with the sentence beginning : " Off-street parking provision ..."
KBBE4 Design 6.5 30 6.2.1. KBBE4: Revise to either remove reference to Policy The AECOM Report has been removed KNP15 the AECOM Report or refer to it as a material change from the KNP, but section 3.1 Design consideration in the design and decision-making Guide has been included in KNP as an process. Appendix.
The status of the AECOM report has been clarified in the Introduction, including an emphasis that any layout plans and site access descriptions were purely illustrative.
KBBE4 Design 6.5 30 Policy KBBE4 Design Policy Reference to HMOs included in the KNP20 with reference to the penultimate paragraph in this change Introduction to Built Environment, and in section, no mention has been made specifit to the Glossary. HMOs.
KBBE4 Design 6.5 30 Cycle storage enabling charging for e-bikes / e- Policy Charging provision added to Policy KNP19 scooters change KBBE4. Space for Battery storage for household power Also addressed in Policy KBT1. management including local Solar power and feeding the grid.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBBE4 Design 6.5 30 Daylighting, although not in the Objective, it should Policy Natural light is referenced in Policy KNP23 be referenced in the text. change KBEF3 - Energy conservation Solar panels can act as skylights, creating both light and energy. https://www.renewableenergyhub.co.uk/main/sol ar-panels/transparent-solar-panels/ This site has interesting information about daylighting and its benefits https://www.wbdg.org/resources/daylighting Bright Ideas: 15 Ways to Introduce Light From Above
KBBE4 Design 6.5 30 Natural air conditioning should also be referenced Policy Natural air conditioning is referenced in KNP23 in the text change Policy KBEF3 - Energy conservation
KBBE4 Design 6.5 30 This refers to ‘vistas’ in the objectives, but there are Policy Changed to 'Views' KNP23 no references to vista in the rest of the document. change
KBBE4 Design 6.5 30 Reword “All parking areas should be capable of Policy Refer to KBEF4 KNP23 being converted to green space in the future”. With change appropriate materials, this should be done from the start. Low growing plants can be grown through paving, or gaps filled with pebbles/gravel that provide shelter and help drainage.
KBBE4 Design 6.5 30 The District Council has a number of concerns with Policy KBBE4 reworded after discussion NHDC this policy. Whilst the Knebworth Neighbourhood with NHDC. Masterplanning and Design Guidelines have been subject to some public consultation during its Policy preparation, it is also clear that the authors have Change recommended that the Parish Council should discuss the design guidelines with the local planning authority in advance of formal
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. consultation and submission. These discussions have not taken place and it seems premature that the policy has been included to state that the Neighbourhood Masterplanning and Design Guidelines will become a statutory part ofthe neighbourhood plan. The District Council would support a policy which encourages developers to use the Neighbourhood Masterplanning and Design Guidelines whilst acknowledging that a significant amount of work is still required in respect of the developments which will come forward for the proposed site allocations in Knebworth. As written, the final paragraph of the policy is confusing. Is the aim of the policy to require developers to provide car parking spaces over and above the standards set out in the emerging Local Plan? It is not clear how it could be proved that a garage space is no longer required for the foreseeable future. The last sentence of the policy could be simplified to state that development proposals resulting in the loss of garages or parking areas will not be supported.
KBBE4 Design 6.5 30 Section 6.5 Policy - KBBE4 Design Policy KBBE4 reworded after discussion HCC There is too much emphasis on parking provision, with NHDC. the focus needs to be on reducing vehicle ownership. Suggesting that parking provision Policy should not include garages is the wrong approach. Change There is insufficient emphasis regarding provision of cycle parking in homes and electric charging for bikes and vehicles.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBBE5 Masterplanni 6.7 31 Masterplanning and Placemaking Policy For HMOs provision for parking must be KNP20 ng and 'Residential parking should be safe and convenient change provided compatible with the NHDCLP Placemaking and should not undermine the quality and amenity and KNP Policies. of streets. Where possible, the predominant parking mode should be on plot, to the side/front in the case of houses, or in parking courts for flats.' No reference is made to avoiding parking problems from HMO applications.
KBBE5 Masterplanni 6.7 31 Section 6.7 Policy - KBBE5 Masterplanning and Cycle parking added to KBBE4 HCC ng and Placemaking Placemaking Cycle parking should be conveniently located at the front of properties. Although reference is made to the need for transport assessments to look at the cumulative impacts of the various developments, Policy this policy has not covered the opportunity to Change masterplan the whole of Knebworth. This needs to be strengthened and refer to rebalancing highway space to facilitate sustainable travel within the village, including looking at opportunities to stop rat runs e.g. Milestone Road.
Site Specific 6.6 31 Section 9 covers biodiversity and the natural The NPPF states that the planning system HCC Planning environment. The Neighbourhood Plan recognises should contribute to and enhance natural Policies the planning drivers that will influence change or environments by minimising impacts on develop opportunities that planning may generate - biodiversity, and providing net which could help to support the natural Policy biodiversity gains where possible. NERC environment through biodiversity net gain and change 2006 includes the ‘duty to conserve enhancement. biodiversity’ which includes ‘restoring or Consequently, for Section 6.6. Site Specific Planning enhancing a population or habitat’ Policies; KBBE5, KBBE6, KBBE7, KBBE8 - any loss of (S.40(3)).The Woodland Trust said semi-natural habitats should consider biodiversity offsetting should only ever be a last offsetting (either on-site or off-site) to mitigate for
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. any impact and to achieve overall biodiversity net resort. gain. Section 6.6 has been deleted.
KBBE6 Site KB1 Land 6.8 32 The policy seeks to add some details to Policy KB1 Item (e) was moved to the Action Plan NHDC at Deards End in the emerging Local Plan. However, the District Council has some detailed concerns Refer also to KBW2 about criterion (e). Whilst we would anticipate that a development on this site would provide open space for recreational use, the emerging Local Plan Policy has no requirement for additional outdoor facilities Change to be provided in Knebworth. Is there sufficient evidence to justify this additional requirement in the neighbourhood plan and has there been any consideration of how such spaces would be managed and maintained in the future?
KBBE6 Site KB1 Land 6.8 - 32 A new outdoor sports facilities including ancillary Policy The AECOM layouts were intended as KNP07 at Deards End e. facilities (toilets, changing rooms and parking for change illustrative and not part of the KNP. 20 cars ) is NOT appropriate in the location Developers proposals for the site have proposed in the AECOM Masterplanning Report, not yet been seen. close to the Conservation Area and Listed buildings and adjoining houses. There will inevitably be noise, traffic/parking issues (with absolutely no chance of on street parking nearby) and light pollution if flood lighting is involved
KBBE6 Site KB1 Land 6.8 - 32 h. seems to be duplicated in second part of g. Policy KBBE6 re-written. These paras no longer KNP07 at Deards End g change included
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. and h
KBBE7 Site KB2 Land 6.9 33 Item g. The introduction of footways along Gypsy Policy Item 'g' removed. KNP24 Off Gypsy Lane is nonsense, the lane has a nominal width of change See also KBT2 Lane only 2.7metres.
KBBE8 Site KB4 Land 6.10 34 For the reasons set out in relation to Policy KBDS02, Policy Policy KBSD02 revised to emove KNP15 East of we do not consider that policy should seek to change references to maximum densities, but Knebworth impose a density limit on development to 28 instead use the phrase 'in sympathy with dwellings per hectare as such a limit could conflict adjacent, existing buildings, so that, on a with national planning policy in relation to density. large site, the density could vary.'.
KBBE8 Site KB4 Land 6.10 34 The policy seeks to reserve for 5.9 hectares for Policy As HCC have stated 'no intent' to site a KNP15 East of school land. However, as a result of the NHLP change secondary school in the part of KB4 Knebworth examination process, Policy KB4 is subject to north of Watton Rd., this area is in several proposed main modifications that are contention between HCC and NHDC. required to make the Plan sound. Specifically, Main KNP has removed reference to any area Modification 288 has removed reference to 4 measurement. hectares of land needed for the school with the See also Policy KBS4 KB4 School Site. policy now stating only that - “land north of Watton Road reserved for long-term secondary education needs”. Therefore, to address this tension, the reference to 5.9 hectares should be removed from the policy.
KBW1 Community 7.2 36 First para (of Policy 7.2) should make it clear that Policy Policy KBW1 ammended: Added into first KNP07 Facilities ALL community facilities would be expected to change paragraph .....' benefit of all residents', so increase proportionately and not just medical and that all community facilities, including public services. medical and public services, 'are increased in proportion' .....
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBW1 Community 7.2 36 Would it be possible to add a section to this policy Policy Inserted new 3rd para: The retention of KNP07 Facilities to emphasise the importance of retaining a GP change a GP Surgery within the village is an surgery in the village? essential requirement when considering any future development proposals.
KBW1 Community 7.2 36 5.2.30 Notwithstanding this, by front loading the Policy Para 2 changed to: 'Development KNP15 Facilities requirement to submit evidence of a potential change proposals will be required to identify impact, this does not factor in that such their likely impact on facilities and assessments would be carried out in any event by services to demonstrate how any such statutory consultees when consulted during the impacts will be addressed, possibly planning application process. including the provision of new facilities, if 5.2.31 As such, Gladman would suggest that rather a shortfall caused by the development has than seek to front load evidence into the planning been identified by a relevant provider, or application process, the policy should be statutory body. This provision should be refocussed to require contributions, or if based on evidenced local needs and necessary, new facilities where a shortfall discussion with KPC and NHDC Planning. caused by the development has been identified by a relevant provider.
KBW1 Community 7.2 36 6.2.1. KBW1: Revise to state that where proposed Policy Development proposals will be required KNP15 Facilities developments result in the need to provide on-site change to identify their likely impact on facilities facilities or a financial contribution to and services to demonstrate how any infrastructure requirements, these should be such impacts will be addressed, possibly consistent with the planning obligation tests of including the provision of new facilities, if Paragraph 145 of the 2019 NPPF. a shortfall caused by the development has been identified by a relevant provider, or statutory body. This provision should be based on evidenced local needs and discussion with KPC and NHDC Planning.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBW1 Community 7.2 36 It is confusing that the overarching section 7.2 title Policy 'Community Facilities' now used KNP07 Facilities and on page 36 is ‘Community Facilities’ (covering all change throughout for internal inconsistency. 7.2.3 facilities mentioned in this section) and then there is a sub-heading 7.2.3. on page 38 also titled ’Community facilities’. 7.2.3 reads more like an introduction to the whole section and might sit better above the green box for Policy KBW1 Community Facilities on page 36.
KBW1 Community 7.2.3 38 It is confusing that the overarching section 7.2 title Policy 'Community Facilities' now used KNP07 Facilities on page 36 is ‘Community Facilities’ (covering all change throughout for internal inconsistency. facilities mentioned in this section) and then there is a sub-heading 7.2.3. on page 38 also titled ’Community facilities’. 7.2.3 reads more like an introduction to the whole section and might sit better above the green box for Policy KBW1 Community Facilities on page 36
KBW2 Local Green 7.3 41 LGS1 policy refers to Knebworth Recreation Ground Policy All instances changed to 'Watton Road KNP07 Spaces whereas 7.3.1 refers to Knebworth Recreation change Recreation Grounds'. i Grounds (plural). Other text refers to Watton Road Recreation Ground/s rather than Knebworth Recreation Ground/s. To avoid confusion, best to stick with one name as per policy. Same applies to Figure/photo names.
KBW3 Recreational 7.4 45 5.2.32 As drafted, the policy stipulates a blanket Policy Added 'in accordance with current KNP15 Green Spaces requirement for “development” to provide new change standards' to first paragraph. greenspaces and recreational areas, which for example would capture minor development including residential extensions. Gladman would suggest that this conflicts with emerging local plan policy that sets out the specific circumstances when
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. open space provision will be required through new development. To ensure consistency with the emerging NHLP, Gladman would suggest that KBW3 should be revised to relate only to “qualifying development consistent with the adopted North Hertfordshire Local Plan”. 5.2.33 As noted previously, if through the Policy the Parish Council wish to refer to development contributions these should acknowledge that these may only be sought when CIL compliant.
KBW4 Assets of 7.5 47 The policy should be deleted. Assets of Community Policy Change to policy wording, para 2. NHDC Community Value are designated outside the planning process Change The assets listed in this policy are Value and any proposed applications could be listed in the already listed, or in the process of being Action Plan. The final sentence of the policy can be listed, with the intention of the listing incorporated into an amended Policy KBW1 - being renewed as necessary. Policy Community Facilities. KBW4 has been renamed 'Valued Community Facilities'.
KBS2 KB2 School 8.3 51 School site. Any development which releases the Policy The KB2 site, proposed by NHDCLP, is KNP24 Site current Swangleys Lane Primary School site should Change ADDITIONAL to the existing Primary be used for public car parking and community School in Swangleys Lane. facilities. Title changes to KBS1 and KBS2 should help to clarify this.
KBS3 Pre-School 8.4 51 There is no requirement in the emerging Local Plan Policy KBS3 reworded NHDC for a pre-school facility to be provided. The policy Policy should be re-worded to state that proposals for a Change pre-school facility in an accessible location will be supported.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBS4 KB4 School 8.5 52 KBS4 (KB4 - Sports pitches) – This KNP policy Policy It is not clear in NHDC LP that this land KNP03 site states that football pitches should be built on KB4’s change will not be removed from Green Belt northern parcel, which is a roughly 350m x 200m unless and until the secondary school is triangle running behind the houses of Knebworth agreed. north of the Watton Rd. It states that the pitches HCC have consistently said that they do should stay there until/unless a school is built. not wish to build a secondary school in There are a number of conflicts of this in terms of Knebworth. both the NHDC LP and delivery. This field is not If this part of KB4 remains in the designated in the NHDC LP for removal from NHDCLP for this purpose, and is removed greenbelt until such time (and subject to) it being from green belt, then the safeguarding delivered for secondary education and I would not clause merely prevents alternative therefore expect it to be readily deliverable from a development. planning point of view. We have committed to The landowner ha said that if a school is NHDC that it would be made available for not built, he will continue to farm the secondary education should this be required and so land. I would imagine you will find they would object to The resolution of this lies between HCC, this KNP policy on the grounds of the practical NHDC and the landowner. implications that it might hinder subsequent conversion. The site has a number of underlying and surface-evident infrastructure utilities (such as a large bore sewer pipes and raised surface inspection chambers). It is also in active agricultural production and is outside of the boundary of any planning application that we would be bringing forward, as it lies beyond the permitted residential area of KB4 and would be currently remaining in greenbelt. In summary, I would urge care in introducing features such as this into the KNP without more detailed analysis and stakeholder discussion with NHDC as it may further jeopardise the approval of the KNP by the inspector and the delivery by NHDC of their LP.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBS4 KB4 School 8.5 52 5.2.34 Through policy KBS4, the KNP seeks to Policy Policy KBS4 reworded, removing KNP15 site control the use of land identified for a secondary Change suggestions for alternative uses, and school through the emerging Local Plan until its requiring that 'Proposals for delivery or the end of the KNP plan period (in development on this site should not be 2031). In the first instance, Gladman would note “inappropriate in the Green Belt,” as that this is not a policy requirement of the emerging defined in the NPPF, until such time as NHLP. Notwithstanding this, the land referred to is the land is needed for a school.' privately owned and in productive agricultural use, Wording added to the text following and intended to remain so until it is transferred into KBS4 reflects the reality of lack of the ownership of the County Council and/or support from HCC AND unavailability of required for use as a school. The land is therefore the land for any other use. not available for the uses suggested. As such, Gladman considers Policy KBS4 is currently undeliverable and in conflict with the Basic Conditions and would suggest that it should be removed from the KNP.
KBS4 KB4 School 8.5 52 Safeguarding the land for education use is Policy KBS4 reworded, removing NHDC site welcomed to ensure long term provision. However, suggestions for alternative uses, and this will be contingent on ongoing discussions with requiring that 'Proposals for Hertfordshire County Council based on projected development on this site should not be need and locational considerations. “inappropriate in the Green Belt,” as The use of the site for recreational purposes should defined in the NPPF, until such time as not compromise educational use in the future. For Policy the land is needed for a school.' instance, it is noted at p.43 in the AECOM report Change Wording added to the text following that a cycle route could be provided through the KBS4 reflects the reality of lack of site. A route skirting the edge of the site may be support from HCC AND unavailability of preferable long term to ensure the site can be used the land for any other use. for educational purposes, if required, whilst HCC objection to KB4 school site can be retaining cycle access. found on this link: https://north-
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. herts.oc2.uk/readdoc/11/searchreprese ntations/14045/5
KBS4 KB4 School 8.5 - 52 As previously stated, I strongly feel that Policy Site allocation defined by NHDCLP. Not KNP07 site 1 ‘exceptional circumstances’ have not been change KNP. demonstrated for the proposed reserved secondary school on site KB4/58 and its release from the It is known that HCC are oposed to a Green Belt is NOT justified during the period of the secondary school in Knebworth, but Neighbourhood Plan or North Herts Local Plan. The NHDC have still NOT withdrawn this fom Green Belt boundary should NOT be changed and the NHDC Local Plan. site 58 should NOT be released from the Green Belt. HCC have also suggested that, as the I am very concerned that the principle of reserving school is not required, then NHDC should site 58 for a secondary school is misguided when it withdraw their application to remove is not clear if the village community actually this site from green belt. Again, there has supports the principle of a small 4 Form Entry been no publicly visible movement on secondary school and Herts County Council has this from NHDC. made it VERY clear during the North Herts Local Plan Examination that it would NOT fund a 4FE See also KBS4, where the supporting text school on the grounds that it is neither academically has been updated, with references, to or economically viable. HCC also advocates that the further explain all of the above. site should remain in the Green Belt and NOT be used for housing. It is not clear if the school would be needed during the term of the Local or Neighbourhood Plan and whether alternative suitable sites or arrangements have been properly considered to justify the allocation. If there is any question that ‘exceptional
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. circumstances’ have not been demonstrated to remove this site from the Green Belt before 2031, then it should remain in the Green Belt and in agricultural use. If it is removed from the Green Belt and reserved for a secondary school and the school doesn’t happen, it is highly likely that the developer will apply to build even more houses on the site at some point in the future.
KBS4 KB4 School 8.5 - 52 Temporary use of the site as playing and sports Policy Site allocation defined by NHDCLP. Not KNP07 site 2 pitches for residents and school children (pending change KNP. it’s eventual possible use as a secondary school) is a red herring. If not needed for education in the Plan It is known that HCC are opposed to a period, it should remain in the Green Belt and in secondary school in Knebworth, but agricultural use. Or remain in the Green Belt for NHDC have still NOT withdrawn this outdoor recreation/sports facilities which are an from the NHDC Local Plan. appropriate use in the Green Belt under the HCC have also suggested that, as the National Planning Policy Framework, should they school is not required, then NHDC should be needed in addition to the other 2 outdoor sports withdraw their application to remove facilities proposed on sites KB1 and 2. this site from green belt. Again, there has This policy mentions an option to link the been no publicly visible movement on secondary school site with the recreation ground – this from NHDC. this seems like a recipe for disaster for the Rec which would become an extension of the school See also KBS4, where the supporting text grounds and be used by pupils at lunch time and has been updated, with references, to after school. further explain all of the above. I would urge the Parish Council to lobby, through the NHDCLP Examination process, for the
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. secondary school proposal to be withdrawn from the NHDCLP and for the boundary to be left as existing so that site 58 remains in the Green Belt.
KBS4 KB4 School 8.5 54 A secondary school will in Knebworth, will cause Policy The designation of 'Secondary School' for KNP27 site the local village atmosphere to change. the change the parcel of KB4 north of Watton Rd Recreation Ground will become an extension of the arises from the NHDCLP, not the KNP. school and will be an additional playground. This Wording added to the text following will not only change the character of our village but KBS4 reflects the reality of lack of will inundate the Recreation Ground with people. support from HCC AND unavailability of Furthermore the village does not have the the land for any other use. infrastructure to support the school population. The proposed entrance road is one priority in aces and the road out towards Hertford is a B road with single track in places. There is also only a Co-op in Knebworth and would not be able to support the existing village as well as a secondary school population.
KBEF1 Biodiversity 9.2 54 What will the test of 'wherever possible' look like Policy Para 4 of the text following the Policy KNP06 re: retain existing trees, hedgerows and green road change specifies this. and has been extended to borders to minimize disruption to wildlife. include: 'Wherever possible means that Have or will some indicators be developed? Will the removal of mature trees will need community have a say on this? justification and access to the sites should be through natural breaks. Removal of hedgerows and verges for access should only be considered as a last resort. In addition, care must be taken to ensure that tree roots are not damaged
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. as they may extend well past the crown of the tree itself. '
KBEF1 Biodiversity 9.2 54 5.2.35 Gladman is largely supportive of this policy. Policy Policy KBEF1 reworded to promote nett KNP15 However, to align with national policy, the Parish change gain, rather than prevent nett loss. Council may wish to consider revising the policy Various Biodiversity calculation tools to state development should aim to achieve a and sources are mentioned in the net gain in biodiversity rather than no net loss. accompanying text. The policy may also wish to signpost to Natural England’s Biodiversity Metric, which is widely accepted as the appropriate calculator to assess biodiversity losses and gains.
KBEF1 Biodiversity 9.2 54 To be in keeping with the existing Knebworth Policy Reference to 'street trees' has been KNP19
environment and to align with the Garden village change included in the text following the Policy. approach the planting of trees, including Street trees, should be encouraged.
KBEF2 Environment 9.4 60 Add a.b.c. bullet numbers to considerations Policy Policy KBEF2 Reworded and bulleted. KNP07 al Pollution change
KBEF3 Energy 9.4 62 5.2.37 As set out in response to Policy KBBE2, Policy The text following KBEF3 has added KNP15 Conservation carbon neutrality in construction and use of new Change context and explanation. buildings remains a longer-term aim of the UK Government and the District Council. This means that at this stage building technology and practices to meet carbon neutrality are not readily viable with only a limited number, of typically small, developments having been possible thus far in the UK. It is however an issue that is attracting close attention and will be developed further over the coming years. To ensure that policies in the KNP do not affect deliverability of development, including
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. on strategic sites allocated in the NHLP, Gladman would suggest that the policy should be geared towards minimising carbon emissions in design, construction and operation or should considered being omitted in favour of these matters being addressed through Building Regulations.
KBEF4 Flooding and 9.5 63 9.3.1 Waterways and groundwater - Most of Policy See also KBEF1 KNP06 Drainage Hertfordshire's drinking water is abstracted from change groundwater. It is also one of the most severely water stressed areas of the country. There is a link between water abstraction and our rare chalk streams in the county running dry. Although some water reduction and SUDs measures are proposed under building design, creating hard surfaces which go to drains, where there was previously a permeable surface which allowed ground water recharge will only add to both localised flooding and continued water resources issues. These two issues should be looked at together (Policy KBEF4 Flooding and Drainage)
KBEF4 Flooding and 9.5 63 Gypsy Lane suffered flooding in the past and this Policy Surface water is referenced in KBEF1 and KNP16 Drainage affected Orchard Way. Additional draining was change KBEF4 provided to fix the problem. The extra buildings probably will cause the problem to re-occur. The water table is high in Orchard Way due to springs and underground streams. Evidence of this is visible on road in Orchard Way and the problem has not been fixed in 3 years.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBEF4 Flooding and 9.5 63 It is assumed that there is a typographical error in Policy Policy KBEF4 amended as suggested. HCC Drainage the following paragraph on p63; change “All development proposals must be designed such that there is at least no net surface water run-off and where possible, a reduction in surface water run-off. Proposals for rain-water storage and re-use will be considered favourably. Proposals that create non-porous ground cover within domestic curtilage, will not be supported.” As it is written it is contradictory but would make sense if it read no net increase in surface water run- off.
KBEF5 Views and 9.6 64 KBEF5 (Views) - I’m not sure I fully understand the Policy Explanation of the views chosen is given KNP03 Character relevance of some of these specific views or what change in the text following KBEF5. Areas exactly is intended to be an acceptable type of protection and whether this KNP policy goes beyond the intention of the Aecom report and beyond the NHDC LP policy. It might be worth reviewing these factors.
KBEF5 Views and 9.6 64 Character Area 1: Picton Houses on east side of Policy 'Oakfields Road' added to Character Area KNP07 Character Stevenage Road: there is no mention of the Picton change 2 Areas Houses in Oakfields Road which are included in the Character Area shaded on the Policies Map.
KBEF5 Views and 9.6 64 Is there any reason why Oakfields Avenue is not Policy 'Oakfields Avenue' added to Character KNP07 Character included in the Character Area 1 as the street scene change Area 3 Areas is similar to Oakfields Road and includes Picton style houses built around the same time as Oakfields Road and Stevenage Road?
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBEF5 Views and 9.6 64 Character Area 2: Park Lane : should this be defined Policy Section title amended as suggested. KNP07 Character as ‘Park Lane (east of A1(M)’. Park Lane is a very change Areas long road.
KBEF5 Views and 9.6 64 5.2.40 Gladman notes that whilst there is some Policy Explanation of the views chosen is given KNP15 Character cross referencing between viewpoints in the KNP change in the text following KBEF5. Areas and the AECOM report, the AECOM report does not AECOM references removed, further provide the necessary justification to support the explanation given. views. For example, for Viewpoint 3 the KNP states that the need to protect this viewpoint is set out in Section 4.6.1 of the AECOM Report. However, the AECOM Report only confirms the need for vistas into the adjacent open countryside to be taken into account given the character these vistas attribute to the village. This commentary broadly reflects the position of the emerging NHLP, which seeks to preserve longer distance views into the open countryside along dry valley to the south of Watton Road and secure boundary treatments to the eastern edge of the development. In Gladman’s view, the findings of both the AECOM Report and emerging policy do not in any way mean that the views outlined within the KNP (namely viewpoints 3 and 5) must be kept permanently open from development, but rather confirms the need for these to be considered through the design process.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBEF5 Views and 9.6 64 6.2.1. KBEF5: Provided further justification can be Policy Explanation of the views chosen is given KNP15 Character provided to support why viewpoints have been change in the text following KBEF5. Areas identified, revise to provide more detail on the 'Where planning applications are made mitigation required to overcome conflict with the in areas where these views and character policy. areas are located (sites KB1, KB2 and KB4), the proposals should provide an assessment of the impact on the existing green infrastructure and wildlife and importantly, the appropriate mitigation measure that will be delivered.' It was considered that the developer would have access to a far larger range of possible mitigation methods than the KNP team (e.g. hedge and tree planting)
KBT2 Traffic Impact 10.3 80 Policy KBT2 - Traffic Impact Wording changed from 'HCC Transport HCC There are some cumulative impact issues that Plan policy' to 'HCC Local Transport Plan would be better as policies for specific 4'. developments to solve. Hierarchy of Transport Users in HCC This policy refers to ‘HCC Transport Plan Policy’ LTP4 covered in justification of KBT2. please refer to Local Transport Plan 4 (LTP4). Wording of KBT2 amended to secure Consideration needs to be given to the policy to funding and if practicable Policy provide a have a more robust link to LTP4 user implementation of schemes before any change hierarchy. properties in developments are occupied. KBT2 refers to improvement measures being implemented before the development of KB1 and KB2 is complete. However, if this is by way of S106 obligations this would not be secure as a developer could avoid the trigger by not building the last house. The wording here needs to be re-considered.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBT4 High Street' 10.5 83 The Doctors surgery is no longer just ‘proposed’, it’s Policy Relevant references to Surgery and to KNP19 (London happened! Change Library, have been up-dated. (Note: The Road) Traffic Reg14 draft for comment was printed in Issues April 2020)
KBT1 Sustainable 10.2 p. 79 Shuttle bus services are unlikely to prove viable in Wording change in Policy KBT1 (delete NHDC Modes of Knebworth without ongoing subsidy, whether from 'shuttle' and insert 'bus'). Travel developer contributions or from HCC’s supported Last sentence of first paragraph of KBT5 bus budget, due to the village size, even when the justification deleted, and replace with new developments are completed. A better 'Diverting the current service 44/45 approach would be to suggest that the policy aim (Luton - Stevenage)through proposed will be that new developments will be served by developments on KB1 and KB2 would local bus services, using existing bus services. An provide public transport to the rail alternative wording of the policy might be ‘and bus station and village centre. services within and between new developments.’ There may be scope to combine future Equally, the proposed suggestion that some bus Section 106 funding from the services will be diverted to via the new developments planned in Codicote, developments in the peak hours is unlikely to which is also served by 44/45 to pay for Policy happen, as most operators do not like deviating service enhancements to the route'. change certain journeys, preferring instead to keep all journeys consistent. Equally, passengers do not like bus services that serve spurs that divert from the main route, or routes that undertake route variations at different times of the day. Instead we would suggest that the 44/45 service could be considered as a potential bus route/s to the serve the new developments, (see below – response to Policy KBT5 Bus Routes). The provision of electric car charging points and shared mobility solutions is also supported by NHDC, in addition to HCC. See NHDC Transport Strategy and emerging EV Charging Strategy.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBBE8 Site KB4 Land 6.10 34 The policy seeks to add some details to Policy KB4 As HCC have stated 'no intent' to site a NHDC East of in the emerging Local Plan. However, the District secondary school in the part of KB4 Knebworth Council has some detailed concerns about the north of Watton Rd., this area is in following criteria: contention between HCC and NHDC. (c) – this criterion requires 5.9 hectares to be KNP has removed reference to any area reserved as a secondary school site, but it is unclear measurement. why this amount of land should be safeguarded. See also Policy KBS4 - KB4 School Site. Policy KB4 in the emerging Local Plan does not Policy include a specific amount of land to be reserved for and Para a secondary school and therefore the change neighbourhood plan must justify why this has been included. (d) – justification would be needed for the requirement for the early years facility and consideration would be needed as to how this would function alongside, or within, the community centre.
KBEF2 Environment 9.3 60 5.2.36 Whilst Gladman acknowledge the intention Policy Policy KBEF2 Reworded. KNP15 al Pollution behind KBEF2, we consider that the informational and Para Text following Policy KBEF2 reworded. requirements it generates would be out-of-scale for change most development proposals likely to come forward within the designated area over the duration of the plan period. To reduce this informational burden on smaller or more minor developments e.g. residential extensions, we would suggest that only developments that would: Contribute significantly to traffic movements; or lead to noise/air quality effects; or are located in sensitive areas (such as close to a source of noise/air pollution or an Air Quality Management Area) should require Noise or Air Quality report. Gladman would however note that
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. the requirements for Noise and Air Quality reports is confirmed within NHDC application validation requirements (See https://www.north- herts.gov.uk/sites/northherts- cms/files/Matrix%20North%20Herts%20District% 20Council%20validation%20requirements.pdf) and would therefore already by provided by qualifying development proposals.
KBEF2 Environment 9.3 60 As the policy is currently written, this policy will Policy KBEF2 Reworded. NHDC al Pollution apply to all planning applications, including those Text following Policy KBEF2 reworded. Policy for extensions or the conversion of a dwelling. Is the and Para intention that this policy should be applied to change planning applications for the Local Plan allocated sites and other major developments?
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBEF4 Flooding and 9.5 63 There are no specific tasks in the action plan Policy KBEF4 and the text following HCC Drainage relating to flood risk and it is not strongly (9.5.1. and 9.5.2) amended. Surface water represented and evidenced in the plan. Although flood maps included as Appendix. mentioned and depicted on maps, the Aecom study does not have any specific recommendations in relation to sites KB2 and KB4. There is mention of road flooding but no mention of recorded or potential property flooding. Flood risk could be more strongly evidenced in the plan and the LLFA following on from this response can help the authors of the plan with flood risk information. The Interpave case study cited for Lamb Drove is in itself misleading. Retrofit is a term more usually Policy applied to installing SuDS in areas that are already and Para developed and built. In the Lamb Drove example change retrofit refers to applying SuDS to a planned site layout rather than integrating it as an integral part of the design process. Similarly use of the terms PFR, PLR and PLP need to be clarified as PFR is the term in current use and broadly covers PLP and PLR. Currently there is no support in the Building Regulations or planning policy to require all new buildings to be resilient to flooding. To follow up on the offer of assistance from the LLFA please contact Andy Hardstaff, Flood Risk Management Team Leader
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBT2 Traffic Impact 10.3 80 5.2.44 Gladman acknowledge that traffic congestion Policy Wording of KBT2 changed to obtain KNP15 is a concern for the existing community in and Para funding for schemes, and implimentation Knebworth. Broadly speaking, Gladman’s principal change if practicable, before any properties are concern with the policy as drafted relates the occupied. expected timing of the off-site improvements to the Schemes added to Action Plan/Section rail crossing point and to key junctions, which it is 106/CIL wish list. stated should occur before developments are completed. 5.2.45 The completion of such improvements will not normally be carried out by the developer e.g. off site junction works would be secured by way of a Section 278 agreement agreed with, and then delivered by the local highway authority. It would therefore be unreasonable to restrict the delivery of Knebworth’s strategic allocations around these timings as it is beyond the developer’s control. Gladman therefore suggests these references are omitted from the KNP or alternatively the Parish Council may wish to seek further guidance from the local planning authority about these issues. Notwithstanding this, where off-site improvements are required, Section 106 agreements will normally include appropriate delivery phasing schedules.
Gen General 1 1 Vision & Objectives – Whilst the draft KNP Policy & It is NOT the aim of the KNP to help KNP03 Comments contains numerous restrictions on the Para deliver developments. A significant implementation of KB4 (and indeed KB1 and KB2) change number of current residents oppose the it doesn’t actually state that it aims to positively proposals in the NHDC Local Plan, which help deliver KB4 per the NHDC LP requirement. I NHDC have nevertheless decided to think that is an important omission. You might want impose on Knebworth. The purpose of to include that positive aim, but caveat it on the the KNP is to ensure that the wishes of assumption that the NHDC LP is ultimately ratified. the community are taken into account
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. This is clearly the overarching goal of the NHDC whenever/wherever any developments LP’s policy for Knebworth. are proposed.
KBDS02 Density of 4.3 20 The policy should be simplified by deleting the 2nd Policy & Policy KBSD02 reworded. NHDC Housing sentence which can Para Development be included in the explanatory text. change
KBBE4 Design 6.5 30 Before leaving this topic, one further example of the Policy & The AECOM Report has been removed KNP03 hazard of including the Aecom findings directly in Para from the KNP, but section 3.1 Design KNP policies is that - being reliant on only Change Guide has been included in KNP as an preliminary and largely desktop-based research – Appendix. Aecom were not aware of the complex network of underground infrastructure that lies under KB4. The status of the AECOM report has been That hidden infrastructure includes large gauge clarified in the Introduction, including an sewers, high voltage electricity cables, large emphasis that any layout plans and site soakaway pipes etc. Our own design efforts have access descriptions were purely been to successfully incorporate these site illustrative. constraints into site layout, but Aecom’s own design would fall foul of them and for that reason was not intended by Aecom as more than an illustration of what might be possible. As you will appreciate, there is a strong basis for de-specifying the Aecom designs and referring instead to design being site- specific and based on the data that is customarily provided at planning application stage.
KBBE5 Masterplanni 6.7 31 If the AECOM Masterplanning & Design Guidelines Policy & The AECOM Report has been removed KNP07 ng and 2019 is to form a statutory part of the Knebworth Para from the KNP, but section 3.1 Design Placemaking Neighbourhood Plan, see comments below re errors Change Guide has been included in KNP as an and concerns that should be Appendix. referenced/acknowledged. Also, there is no provision to allow for an updated/alternative The status of the AECOM report has been Masterplanning document which may become clarified in the Introduction, including an
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. necessary if this one becomes outdated, either emphasis that any layout plans and site because of changes in National or District policies access descriptions were purely or because development of all or some of the illustrative. proposed housing sites are delayed until later in the Plan period, possibly due to a downturn in the economy and housing markets following the coronavirus pandemic. Government policy and technological advances on such matters as air pollution and climate change will inevitably change in coming years and may not be adequately covered by the AECOM Report.
KBBE5 Masterplanni 6.7 31 5.2.24 To remedy these concerns, we would suggest Policy & The AECOM Report has been removed KNP15 ng and two potential options. The first, would be to Para from the KNP, but section 3.1 Design Placemaking remove masterplans from the AECOM document Change Guide has been included in KNP as an and the latter part of Policy KEBBE5. Appendix. Alternatively, the policy could be revised to acknowledge that the masterplans show “one The status of the AECOM report has been potential option” of how the sites may be clarified in the Introduction, including an developed, subject to further understanding of emphasis that any layout plans and site known site specific issues and engagement during access descriptions were purely the planning application process. In this regard, illustrative. Gladman remains committed to positively engaging with the Parish Council when preparing an application for site KB4. 5.2.25 Either approach would provide the necessary flexibility to ensure that the design process can be concluded without prejudice for the proposed allocation sites in Knebworth, therefore safeguarding deliverability.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBBE5 Masterplanni 6.7 31 6.2.1. KBBE5: Remove or amend references to the Policy & The AECOM Report has been removed KNP15 ng and masterplans set out within the AECOM Report to Para from the KNP, but section 3.1 Design Placemaking being potential design options for the development Change Guide has been included in KNP as an of the strategic allocated sites. Appendix. The status of the AECOM report has been clarified in the Introduction, including an emphasis that any layout plans and site access descriptions were purely illustrative.
KBBE8 Site KB4 Land 6.10 34 Mr xxx objects to the inclusion in Policy KBBE8 of Policy & Status of the AECOM report, particularly KNP04 East of the submission version of the Knebworth Para any layout suggestions and site access Knebworth Neighbourhood Plan of Swangleys Lane for site change suggestions, has been clarified in the KNP access to the proposed site allocation KB4. Introduction. 3. Mr xxx refers to and relies upon the attached Highways Appraisal produced by Glanville Consultants, expert multi-disciplinary consultancy. 4. Swangleys Lane is a narrow residential and rural road. It has significant constraints in terms of carriageway width, on-street parking, speed limits, visibility, junction separation, level differences, safety and sustainability. Mr xxx maintains that it is completely unsuitable for site access to the proposed site allocation KB4. 5. Criterion b in Policy KBBE8 should therefore be amended to the following: “2 site accesses on Watton Road and Old Lane;” 6. The opening words of Policy KBBE8 assume that the draft North Herts Local Plan will be adopted, even though the examination has not finished and even though the Inspector has not yet reported. The reference to “KB1” is also confusing. The opening words should therefore be amended to the
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. following: “Land allocated in the draft North Herts Local Plan, identified as KB4, should if allocated for residential development in the adopted North Herts Local Plan be developed…” 7. Please also note that there is no apostrophe in Swangleys Lane (criteria f and g refer).
KBBE8 Site KB4 Land 6.10 34 For the reasons set in relation to or response to Policy & Status of the AECOM report, particularly KNP15 East of Policy KBBE5, we do not consider that there should Para any layout suggestions and site access Knebworth be a requirement to develop the Site in accordance Change suggestions, has been clarified in the KNP with the AECOM Report Masterplan. This instead Introduction. should be shown as a potential option.
KBBE8 Site KB4 Land 6.10 34 Weight given to Site Access Appraisal. Whilst the Policy & Status of the AECOM report, particularly KNP15 East of policy requires site access to take account of the site Para any layout suggestions and site access Knebworth access appraisal, Gladman note that the AECOM Change suggestions, has been clarified in the KNP report is caveated to state its “assessment is based Introduction. on observations made on site and through Access points in the AECOM report are reference to imagery provided by Google Maps. As indicative only. such the advice set out in this note is preliminary in KBT2 supports the production of Traffic nature…(AECOM Report, page 44)” As neither Assessment that will contain an access Gladman nor the landowners have been strategy. approached by a highways consultant acting on behalf of AECOM we are unaware whether AECOM’s guidance has had input from the Local Highways Authority. Notwithstanding this, to establish the parameters for the Site access now and ahead of site-specific discussions could hinder this process and could ultimately lead to a position that jeopardises the deliverability of the Site. Gladman is currently in ongoing dialog with Hertfordshire
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. County Council about the accessibility requirements of the Site. This will ultimately feed into the Transport Assessment submitted as part of the planning application to develop the Site as well as the access strategy arrived at in consultation with the Local Highways Authority and Parish Council.
KBBE8 Site KB4 Land 6.10 34 6.2.1. KBBE8: Revise to reflect the up to date Policy & Status of the AECOM report, particularly KNP15 East of position of the NHLP. Amend references to the Para any layout suggestions and site access Knebworth AECOM masterplan, AECOM site access appraisal, Change suggestions, has been clarified in the KNP community centre and pre-school nursery and Introduction. clarify the expectations of the link from the school to the recreation ground.
KBW1 Community 7.1 L 35 For consistency with Section 7.2 this objective Policy & Community Facilities' now used KNP07 Facilities should also refer to ‘community facilities’. Would be Para throughout for internal inconsistency. helpful to define community facilities and amenities Change in the glossary.
KBEF3 Energy 9.4 62 6.2.1. KBEF3: Revise to encourage energy Policy & Covered by changes to policy KBBE2? KNP15 Conservation efficiency lending support to schemes that are able Para to demonstrate this through the design, change construction and operation.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBEF5 Views and 9.6 64 5.2.41 Turning to viewpoint 4, protection is sought Policy & Explanation of the views chosen is given KNP15 Character by the KNP to this viewpoint following the findings Para in the text following KBEF5. Areas of the AECOM Access Appraisal. Setting aside change AECOM references removed, further comments already made in relation to the AECOM explanation given. Access Appraisal, should the Site be accessed in line Viewpoint 4 is looking west along Watton with the high level recommendations of AECOM, the Road from Bell Close. This view is protection sought by the KNP to viewpoint 4 would unlikely to be affected by an access to likely render this access solution undeliverable, any proposed development. It should be therefore contradicting Policies KBBE5 and KBBE8 possible to plant new trees behind any of the KNP respectively. necessary sightlines to maintain the tree- 5.2.42 To remedy the tensions identified, the most lined effect. straightforward option would be to delete the views (3 and 4) from the KNP. Alternatively, provided appropriate justification can be generated to support why the key views are important, the Parish Council may wish to consider including additional guidance either within the policy or its supporting text that defines the form of mitigation that would be required to overcome any conflict with the policy. That would assist applicants and decision makers interpretation of the policy and may prevent any conflicts between the policy and the deliverability of strategic allocated sites.
KBBE5 Masterplanni 6.7 31 We would recommend that it requires new Added references to ‘Manual for Streets’ HE ng and developments to, as a minimum, follow the and ‘Manual for Streets 2’. Placemaking principles of the government’s best practice advice Policy & https://www.gov.uk/government/public on urban design, which is Manual for Streets and App ations/manual-for-streets into the text Manual for Streets 2. Within conservation areas or change following Policy KBBE5 other areas of historic interest we would recommend that regard is had to Historic England’s advice note “Streets for All: Advice for Highways
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. and Public Realm works in Historic Places
KBEF5 Views and 9.6. 72 There should be an image of Oakfield Road houses Photo Amended as suggested. KNP23 Character as well change Areas
KBEF5 Views and Fig 74 Neither photo shows housing mix as it is difficult to Photo Caption changed. KNP07 Character 57 see the houses. change Areas
KBEF5 Views and 9.6 64 Green Infrastructure Green Infrastructure is referred to in HCC Character Green Infrastructure (GI) is listed in the glossary, KBBE5, KBEF1 and KBEF5 Areas however, does not appear to be addressed anywhere within the plan. This is a fundamental issue as GI assets and networks are fundamental to Para high quality sustainable placemaking. changes The plan refers to important local landscape features such as tree lined streets and local walking routes, which are important GI assets and connections, and should be mapped and protected and enhanced through policy.
Objecti Objectives L 18 See comments below on page 36. For consistency Para Community Facilities' now used KNP07 ves with Section 7.2 this objective should also refer to change. throughout for internal inconsistency. ‘community facilities’. Would be helpful to define community facilities and amenities in the glossary.
KBT5 Bus Routes 10.6 84 It is considered that Arriva are unlikely to divert the The text following KBT5 has been NHDC 300/301 from the main B197 London Road as these Para amended to suggest that Route 44/45 routes are inter-urban services which usually keep change. (Luton - Stevenage) is diverted through to the main roads. An alternative approach might be proposed developments on KB1 and KB2
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. to consider variations to the 44/45 (Luton – and if possible enhanced providing Stevenage) services as more appropriate to serve public transport to the rail station and the proposed allocations. There might also be scope village centre. There may be scope to to combine future s106 funding from the combine future Section 106 funding from developments planned in Codicote, which the the developments planned in Codicote, 44/45 also serves to pay for service enhancements, which is also served by 44/45 to pay for thus benefiting the route throughout which in turn service enhancements to the route'. will add to the longer term viability of the service, after any developer contributions have expired.
Gen General 1 1 Greenbelt development is understandably highly Para Some slight change in emphasis has been KNP03 Comments contentious and we are always sympathetic that change included in the Introduction'. some people will never support this. However, the To expect the residents and their decision has been taken by NHDC to seek to develop representatives to 'positively embrace' KB4 . And, after Local Plan adoption, it will be the NHDC decision is asking a bit much! enshrined in planning policy under the NHDC LP We DO, however, 'positively embrace' the that KB4 should indeed come forward for process of ensuring that residents development. Consequently, we would anticipate opinions have been captured and will that both the PC and KNP team positively embrace contribute to the creation of any new that fact and positively aide the implementation of a developments. quality development of KB4.
Gen General 1 1 6.2.1. Revise references in (to) the AECOM report Para The AECOM Report has been removed KNP15 Comments as being a statutory part of the KNP. As this is an change from the KNP, but section 3.1 Design evidence base document used to inform policy, we Guide has been included in KNP as an do not consider this is possible. Appendix. The status of the AECOM report has been clarified in the Introduction, including an emphasis that any layout plans and site access descriptions were purely illustrative.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
Gen General 1 1 Various spelling of Swangleys Lane. Needs to be Para Typographical. Find and Replace. KNP23 Comments consistent. Google maps shows it with as Change “Swangley’s Lane”
Gen General 1 1 Quite a few lists and paragraphs are separated by Para Typos, for correction. KNP23 Comments “;”. Should this be “,”. E.g. Policy KBBE6 Site KB1 Change Land at Deard’s End
Gen General 1 1 2. There is a significant amount of explanatory text Para The explanatory text has been reduced, NHDC Comments throughout the plan. Consideration should be given Change by replacing quotations with references, to moving some of this text into appendices which particularly regarding the AECOM report, will help to focus the neighbourhood plan on the which has been removed, (apart from proposed planning policies. section 3.1, which has been left as an appendix), but also by eliminating repetition.
Gen General 1 1 • To reduce car use and overall traffic levels; A Para Added to Projects/Tasks table : - 'Set up CPRE Comments sustainable travel group might be set up to Change Master Planning group that covers continually drive and monitor progress for the sustainable transport for the village' whole village, not just for new areas. With the climate crisis the objective of modal shift will be an integral objective of all plan,. See Decarbonising Transport March 2020 – Dept of Transport. Relying on technology alone (e.g. electric cars), won’t address the climate emergency or realise the other benefits (environmental, safety, amenity, air quality, health, etc) of a modal shift to sustainable travel. Measures might include an expanded role for electric cycle use, cargo bikes for freight, electric or hydrogen public transport, local electric car pools. Road space reallocation or filtered ‘quietway’ routes as part of a network for walking and cycling.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. Aspirations for improved public transport, local shuttle routes, or quasi taxi services.
Gen General 1 1 • To improve design standards the reference to Para Added to references CPRE Comments Building for Life 12 is helpful. Another more recent Change publication that could be referenced is the Place Alliance Report UCL The Ladder of Place Quality 2019. This is evidence-based research on what delivers good quality.
Gen General 1 1 Manual for Streets has already been referenced in Para Added to references: Useful reference to CPRE Comments the plan. A further good reference for the design of Change consider when designing scheme for rural streets and village centres is Traffic in Villages High Street. (Stonehouse, Gloucestershire – a toolkit for communities. While produced for good example of what can be achieved) Dorset, the principles apply more widely.
Gen General 1 1 HCC has a number of concerns that the Para The Neighbourhood Plan is drawn up to HCC Comments Neighbourhood Plan does not conform with the Change conform with HCC LTP4 where possible Hertfordshire County Council Local Transport Plan and follows the hierarchical transport 4. approach for new developments. However, the Neighbourhood Plan is primarily based on the requirements of Knebworth and its residents.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
Gen General 1 1 Master planning Approach Para Added items to Projects/ Tasks table, HCC Comments The Knebworth Neighbourhood Plan should be Change plus wording change. ('It also offers an seeking to create a masterplan for Knebworth in the opportunity to develop a multi-modal context of the proposed growth to ensure that a approach towards sustainable transport holistic view for a package of measures is required in the village and its surrounds.) for the village. This could include proposed diversions of buses, routing of cycle links from Funding for a an holistic transport plan developments to the proposed B197 sustainable was not forthcoming. corridor and NCR 12 along with upgrading walking routes connecting residential areas to the High Creating a Masterplan for transport for Street and rail station. This would allow for a more the whole Plan area was not within the holistic view of sustainable transport for the village remit of the Neighbourhood Plan. The and allow for funding to be gathered from all future Parish Council would be happy to discuss developments and benefit the village. Consideration with HCC improvements to, and should also be given on the implementation and enhancement of existing active transport promotion of these changes across the whole routes in the Plan area. The justification village. of KBT1 ('Sustainable Modes of Travel' There are opportunities to develop a multi modal and the Action Plan (Appendix C) cover approach towards sustainable transport, however, some of the items raised. There is also a there does not appear to be a strategic level 'wish list' of items not put forward in the approach to modal shift which will need to be Action Plan that includes such items. considered. Accessibility by all modes of transport should be given consideration in securing the right balance.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
Gen General 1 1 Master planning Approach - (Contd): Alongside the Para Added reference in para, and to Appendix HCC Comments relevant sustainable transport infrastructure, the Change strengthening of policies in the Neighbourhood Plan which promote sustainable modes and create a foundation for change in travel behaviour is key. Policies should encourage and enable shorter journeys (including those by existing residents) to be made by sustainable means, including by walking and cycling, given the wider community benefits of active travel Other Comments The Knebworth Neighbourhood Masterplanning and Design Guidance (Feb 2019) which has been used to provide assistance in producing the Neighbourhood Plan and forms a statutory part of the plan, Section 2, Policy Review includes the emerging North Herts Local Plan but does not make reference to Hertfordshire County Council LTP4 as outlined above. Hertfordshire County Council Highways would welcome the opportunity to work together to develop a plan that contributes to the overall vision for Hertfordshire.
Gen General 1 1 1. There are a number of policies throughout the Changes to wording of Policy KBW5 to: 'A NHDC Comments neighbourhood plan which state that proposals “are minimum of 1.5 Ha of land will be sought likely to be supported” or “likely to be opposed”. for use as allotments across all proposed The District Council considers that this does not Para major development sites, to meet local provide sufficient clarity when a development change identified demand.' proposal is being considered; will a proposal be The wording of KBT1, KBT2, part of supported or will it not? Policies include KBLE1; KBT3, and KBT5 have been altered to KBLE2; KBLE3; KBLE4, KBW5, KBT1, KBT2, KBT3, avoid having to 'support' the KBT5. There is some useful guidance prepared by development if policy met. Policies now
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. Locality on writing planning policies which might state what the development 'should' be helpful in addressing this issue: provide. In KBT3 developments that fail https://neighbourhoodplanning.org/toolkits-and- to provide NHDC's minimum off-street guidance/write-planning-policies-neighbourhood- parking provision will not be supported. plan/
Gen General 1.3 8 Minerals & Waste The supporting text for KBEF3 has been HCC Comments Section 1.3 of the neighbourhood plan reviews amended. relevant national and local policy. It should be noted that the Minerals and Waste Local Plans form part of the development plan for Hertfordshire. These documents currently include: • Adopted Minerals Local Plan (2002-2016); • Waste Core Strategy and Development Management Policies Document (2012); and • Waste Site Allocations Document (2014) Although neighbourhood plans cannot include policies that cover Minerals and Waste development, the Local Plans should be considered Para as relevant documents within the neighbourhood change plan. While there are no identified waste management sites within the neighbourhood plan area, waste and planning for waste is still an important consideration. The county council, as Waste Planning Authority, supports objective G of the plan. The re-use of building materials is a useful way of reducing waste arising from developments and can enable more sustainable construction. The theme of sustainability running throughout the document resonates that an aim is to minimise waste. This statement promotes a Circular Economy and better waste management for the area.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. Similarly, the county council is in support of KBEF3, although it is felt that the policy’s supporting text could be expanded to include more information around the re-use of building materials or reference key documents that guide this principle. KBBE4 includes a useful statement regarding bin storage provision. All buildings should design in sufficient space for bin storage and space for full recycling and waste separation. As stated in previous comments, part of the Neighbourhood Plan Area falls within the Sand and Gravel belt with south west of the area falling within a mineral resource block. The extend of the block and buffer is shown in the county council’s adopted Mineral Consultation Areas, Supplementary Planning Document. This is an area of the county where particular care is needed to prevent the unnecessary sterilisation of sand and gravel resources. In these areas, before planning applications are decided by the district or borough councils, the county council will be given the chance to consider whether the development proposed would lead to unacceptable sterilisation of mineral resources. Minerals Policy 5: Sterilisation, of the adopted Minerals Local Plan 2002-2016 addresses the need for prior extraction of minerals to ensure that the resource is not sterilised.
Intro Introduction 2.2 13 Shouldn’t this actually be part of 2.1? i.e. 2.1.5. Para Implemented as suggested. KNP23 Change
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
Intro Introduction 2.3 15 The importance of trees is highlighted by the RHS Para Supporting text for 9.2 includes 'street KNP23 Garden magazine, April 2020. It states that trees act Change trees'. as parasols, so that the ground can be 12oC cooler in the shade, while denser canopies have a more cooling effect. Buildings shaded by trees absorb and store less heat. Shelter from green roofs or climbers help to cool a building. Temperatures can be 3-4oC below a green roof. Climbers on an ivy covered wall can be 36% cooler than a bare wall.
Intro Introduction 2.4 16 The population should be ‘Knebworth Parish’, Para The para has been changed to say KNP23 rather than Knebworth Change 'Knebworth Parish has a population …'
Vision Objectives 3.1 17 6.2.1. Vision and Objectives: Revise to make Para The Knebworth Neighbourhood plan KNP15 reference to housing need and the need to support Change makes a number of references to housing the delivery of the spatial strategy of the NHLP so need, and in particular refers to the need far as it is relevant to Knebworth, including the to consider the Strategic Housing Land delivery of new homes at KB1, KB2 and KB4. Availability Assessment (SHLAA), the Knebworth Housing Needs survey, and the Knebworth Estate Agents Survey. The KNP also covers the community needs for development proposals outside the NHDC Local Plan proposals.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
Vision Vision 3.1 17 Gladman note the vision and objectives of the Para The act of creating the Neighbourhood KNP15 KNP. However, we would suggest that these could Change Plan supports the delivery of the be bolstered by a reference and commitment within NHDCLP stated number of houses for them to ensuring that that sufficient housing is each proposed area, but that support is provided within the plan period to meet local conditional on submitted plans meeting housing needs and the requirements of the the Policies of HCC, NHDC and the emerging NHLP. Such an addition would align the Neighbourhood Plan. vision to meeting basic conditions (a), (d) and (e), as the delivery of new homes is core priority of the NPPF and a key issue in North Hertfordshire. The absence of housing need and supply within the Vision and Objectives of the KNP creates tension with national planning policy and strategic policies of the Local Plan. One option to achieve this would be to amend the vision to include a commitment to ensure that local housing needs are met in full, providing a range of high-quality new house types, sizes and tenure, and secured affordable housing delivery. This commitment could also reference sites that have been allocated for development in Knebworth - KB1, KB2 and KB4, which should be delivered in full by the end of the KNP plan period in 2031.
Object Objectives 3.2 17 Section 3.2 - Objectives Para Added KBT1 and KBT2 to Objectives J HCC The objectives developed to support Knebworth change and L. Neighbourhood Plan for the Traffic, Transport and Added KBT1 to Objectives J, L, M, O and Parking Policies are P, Q and R. However, the P. objectives below are those considered to be Added 'and prioritise active travel primarily related to transport but there are a throughout the Plan area'. greater number of the objectives that could be Improvements mentioned in the last assisted if transport paragraph are for HCC to undertake. infrastructure/accessibility/routing were also
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. considered alongside them. Objective R should also include the prioritisation of active travel. J. Create attractive, easily accessible safe neighbourhoods through good design following the principles of ‘Placemaking’ K. Seek cost effective and innovative solutions (underground parking in major developments) to minimise the amount of land taken up with car parking P. Find a solution to the ‘high street’ traffic and parking problems Q. Negotiate for the provision of disabled access to rail station platforms R. Support and encourage use of sustainable modes of transport including ensuring access roads through new developments are suitable for bus routes The draft NC GTP aligns with objectives J, P and R including a package of highway layout changes on the ‘high street’ to improve bus journey time reliability (PR28), the development of a sustainable travel corridor along the B197 including better access from the village to the station by sustainable transport (SM93) and the need for direct and attractive cycling and walking routes from the new developments to the railway station, bus services and cycle routes (SM94).
Object Objectives K 17 Underground parking should be encouraged on all Para example removed from Objective K. KNP24 developments. Change Suggestion remains in Policy KBBE5
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
Object Objectives 3.2 17 Knebworth Football Club strongly supports this Para Added to Action Plan KNP18 objective. We have run for years at a capacity which Change exceeds the Parish’s available facilities, and winter training facilities must be rented exclusively outside the Parish. The new development represents a major opportunity to enhance the Parish’s recreational facilities for the benefit of all users, including but not restricted to the Football Club.
Object Objectives 3.3 18 There should be a ‘.’ After Appendix B. Para Amended as suggested. KNP23 change
Object Objectives 3.4 18 There should be a ‘)’ after the reference to Appendix Para Typo, for correction. KNP23 A. change
Object Objectives K 18 Add ‘e.g.’ before underground parking as per K. on Para example removed from Objective K. KNP07 page 27. This should be consistent and reflect that it change Suggestion remains in Policy KBBE5 is only a suggested example. Also see K. p 53.
Object Objectives New 18 Add new objective to identify options and seek Para This requirement is covered in the Action KNP07 provision of an indoor sports/leisure facility with change Plan and Community Priority List. all-weather pitch as per Appendix Action Plan/4. Clearly this aspiration has land use implications and as it is not covered in the AECOM Masterplanning Report, specific requirements should be identified on site size, access/transport criteria etc, whether or not it is co-located with one of the schools. If neither school goes head it should still be an objective and a site secured by negotiation or through S106 agreement.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBDS01 Retention of 4.2 19 Policy KBDS01 Retention of Separation Between This has been clarified in the Main CPRE Separation Settlements Introduction, at the end of 1.3. Between (and also Built Environment Policies KBBE6, Settlements KBBE7 and KBBE8) The loss of large areas of Green Belt countryside at sites KB1, 2 and 4 is an objection for CPRE Herts Para while it is noted that the Neighbourhood Plan is change being produced to align with the, as yet, unadopted North Herts DC Local Plan which is still subject to Examination. CPRE Herts has objected to North Herts DC’s approach and justification for releasing land in the Green Belt in the Local Plan. Clearly there is a key question of prematurity.
KBDS02 Density of 4.3 20 If the AECOM Masterplanning & Design Guidelines Para The AECOM Report has been removed KNP07 Housing 2019 is to form a statutory part of the Knebworth change from the KNP, but section 3.1 Design Development Neighbourhood Plan, see comments below re errors Guide has been included in KNP as an and concerns that should be Appendix. referenced/acknowledged. Also, there is no provision to allow for an updated/alternative The status of the AECOM report has been Masterplanning document which may become clarified in the Introduction, including an necessary if this one becomes outdated, either emphasis that any layout plans and site because of changes in National or District policies access descriptions were purely or because development of all or some of the illustrative. proposed housing sites are delayed until later in the Plan period, possibly due to a downturn in the economy and housing markets following the coronavirus pandemic. Government policy and technological advances on such matters as air pollution and climate change will inevitably change in coming years and may not be adequately covered by the AECOM Masterplanning Report.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBLE2 Rural 5.3 22 Delete “existing” before national, Local Plan and Para Existing' removed NHDC Businesses Neighbourhood Plan policies… Change
KBLE3 Village Centre 5.4 23 Section 5.4 KBLE3 reworded HCC and Existing The first paragraph under KBLE3 refers to the need LPT4 referred to in KBT1 Businesses for the village centre businesses to be supported by These measures help facilitate adequate road frontage and parking. Simply sustainability of these businesses by focusing on parking would be incompatible with allowing through traffic from small LTP4 it may also increase the attractiveness of nearby settlements to access them. This driving to the centre and increasing congestion trade would otherwise be lost. which would be contrary to other aspirations in the Para The bulk of traffic using the 'high street' draft plan. Making provision for people to travel to Change does not stop in the village, as it is simply the centre by more sustainable modes such as through-traffic on the B197, Stevenage- walking and cycling is important, particularly for Welwyn and beyond. residents making shorter journeys and would Item added to Projects/Task List. support KBT1. The text underneath KBLE makes no reference to LTP4 or the hierarchy which emphasises the need to reduce travel in Policy 1.
KBLE3 Village Centre 5.4 23 The wording of the 3rd sentence should be KBLE3 reworded NHDC and Existing amended to include the formal name of the “high Businesses street”: Para The loss of retail frontage in the Retail Area as change defined on the Policies Map (London Road and Station Road) ….
Object Objectives 6.1 K 27 This wording includes ‘e.g’ before underground Para example removed from Objective K. KNP07 parking. It is different to the wording in Objective K. change Suggestion remains in Policy KBBE5 on page 18. See note above. I agree that the wording should include ‘e.g’. Also see page 53.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBBE4 Design 6.5 30 We would suggest that the wording is altered Policy KBBE4 reworded. HE slightly, however, as new buildings being “sympathetic in design to surrounding buildings” Para may lead to the continuation of mediocre design, change whereas presumably the policy wishes to encourage enhancement where possible.
KBBE5 Masterplanni 6.7 31 Policies KBBE5 Masterplanning & Placemaking Street tree planting has been included in CPRE ng and (and also Policy KBEF1 Biodiversity & Policy KBEF2 the text following KBBE5 Placemaking Environmental Pollution) Street tree planting is an acknowledged Para government objective and should be included as Change part of the work to strengthen green infrastructure /greening of the village. It also helps mitigate pollution and support wildlife.
KBW1 Community 7.1 35 3rd para, last line – change ‘area’ to ‘are’ Para Changed as suggested KNP07 Facilities change
KBW1 Community 7.2.4 40 "The following facilities and amenities have Para Paragraphs 6 and 7 reworded to clarify KNP07 Facilities - 7th been identified as needing expanding or change this para improving…" : it is not clear what these are as there is no list included in this section.
KBS1 Primary 8.2 50 The benefits of combining with the nursery has Para Titles of KBS1 and KBS2 changed for KNP16 School been recognised. Further benefits can be obtained change clarification. by amalgamation with the senior school both in terms of facilities and access to specialised teaching resources. A school in St Albans gives the opportunity to have a French teacher visit for a short period of time Primary schools in the local area. (Declare an interest)
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBEF1 Biodiversity 9.2 54 Expand second paragraph to cover planting of Para 6th Para of text following KBEF1 refers KNP23 gardens (and also reflect in Policy KBBE4 Design – Change to landscaping, SuDS planting and Street probably best to reference this section to avoid trees. duplication) to encourage a healthier ecosystem by using a wide variety of plants attractive to wildlife. This includes having a mix of evergreen and deciduous planting as well as perennials, shrubs and suitable trees rather than a monoculture. Care must be taken to ensure that trees and shrubs are planted appropriately for their use and ultimate size. https://www.rhs.org.uk/science/conservation- biodiversity/plants-for-bugs https://www.rhs.org.uk/science/conservation- biodiversity/wildlife/plants-for-pollinators The benefits of having a green space has been demonstrated by the Covid 19 pandemic and is backed up by a lot of research into Vitamin G (RHS the Garden April 2020 summarises this in ‘The healing power of gardens). https://www.rhs.org.uk/advice/health-and- wellbeing/articles/why-gardening-makes-us-feel- better It should also state that plants should be UK grown to help prevent importation of diseases (e.g. Xylella which can affect many species). Where possible, bare root plants and/or eco packaged plants should be selected.
KBEF1 Biodiversity 9.2.4 59 (Preferably native) can be replaced by (Preferably Para Amended as suggested. KNP23 . native or near native). Note Horse Chestnut is not change
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. actually a native. Reference RHS The Garden March 2020
KBEF2 Environment 9.3 60 There is a statutory obligation on NHDC to monitor Para Text following KBEF2 has been amended KNP16 al Pollution and control pollution. Clearly it is important that change to include constant monitoring in specific the starting point is analysed. This is particularly areas.
important in the cases of the Shopping precinct and the A1. It is important that constant monitoring equipment is used as stated by Defra as the use of Diffusion tube technology (cigar shaped lighting poles) is both insensitive to variations and a waste of money for traffic problems. A government report has stated that if pollution levels exceed the directives, consideration should be given to road closures.
KBEF3 Energy 9.4 62 The importance of trees is highlighted by the RHS Para The text following KBEF3 has been KNP23 Conservation Garden magazine, April 2020. It states that trees act change amended. as parasols, so that the ground can be 12oC cooler in the shade, while denser canopies have a more cooling effect. Buildings shaded by trees absorb and store less heat. Shelter from green roofs or climbers help to cool a building. Temperatures can be 3-4oC below a green roof. Climbers on an ivy covered wall can be 36% cooler than a bare wall.
KBEF4 Flooding and 9.5 63 The area at the bottom of Swangleys Lane, Para Surface water is referenced in KBEF1 and KNP26 Drainage Milestone Road and St Martins Road is already change KBEF4 subject to flooding during heavy rainfall, with sandbags required for the local businesses situated there. Building on the KB4 site, in its elevated
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. position, will cause even more surface run off, increasing the likelihood of flooding even further. Orchard Way's flooding problems have still not been resolved, many years after the development was built.
KBEF5 Views and 9.6 64 Would it be possible to add directional arrows to Para Directional arrows added to Policies Map KNP07 Character the Policies Map Shaded Area for each of the listed change Areas views?
KBEF5 Views and 9.6 64 5.2.38 Policy KBEF5 establishes 10 key views and Para Explanation of the views chosen is given KNP15 Character two-character areas to be protected from “negative change in the text following KBEF5. Areas impact of development”, with development affecting these key views/character areas “requiring appropriate mitigation measures in order to be approved”. Whilst these views have been identified, Gladman has been unable to find the evidence or justification that has determined what makes these “key views”. 5.2.39 For example, it is unclear on what basis Key View 1 is sought for protection. The view is from a private nursery, some distance from Knebworth. The view protected is extensive though not particularly uncharacteristic for the local area and is already subject to the protections afforded by it being within the Green Belt.
KBEF5 Views and 9.6 64 Parish; should be “parish:” Para Amended as suggested. KNP23 Character change Areas
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBEF5 Views and 9.6 64 Overall there is concern for the lack of detailed Text associated with KBEF5 has been HCC Character evidence and reference to industry good practice reviewed and expanded. Areas and standards underpinning policy requirements, which leaves them open to interpretation and difficult to enforce, as discussed in more detail below. The identification and mapping of key views is Para supported in principle. It would be beneficial to see change the viewpoint symbols on the map amended to show the viewshed, so that the distance and extent of the view can be better understood. This would highlight the nature of the view, for example if it is channelled by existing features or focused on a landmark etc. which is important to understand in order to positively manage change that affects it.
KBEF5 Views and 9.6 64 There should be reference to the existing North Text following KBEF5 revised, Landscape HCC Character Hertfordshire Landscape Character Assessment, Character reference added. Areas that is carried out at a District level and should 'Knebworth village lies within Landscape provide the framework for a more local level Character Area 37 ‘Datchworth Settled assessment for the NP area. For each local character Slopes’ in the North Herts Landscape Para area, it should be clear what the existing positive Study (NHDC, 2011)' change and negative characteristics of each area are, to Land Character Assessment of North ensure that any change conserves and enhances the Hertfordshire (page 63-66) character and quality of the area. This could inform http://www.stevenage.gov.uk/content/1 a design code to guide change, such as new 5953/26379/45609/Area-208.pdf development, within each area.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBEF5 Views and 9.6 64 In the last paragraph, it is unclear in the policy what Picture of Oakfields Road included. NHDC Character might be defined as “negative impact”. Other comments received suggest there Areas To help simplify the neighbourhood plan, is insufficient detail given for each view. consideration should be given to moving the To move all of this to an Appendix, would supporting information for the views and the exacerbate that problem. character areas into an appendix to the neighbourhood plan. This will help to retain the Para focus of the plan on the policies. change In terms of Character Area 1, the Picton Houses on the east side of Stevenage Road, the photographs and the description relate to this description but the character area on the Policies Map shows that the area includes Oakfields Road as well. It would be helpful if this was illustrated as well.
KBEF5 Views and 9.6 65 There are also two important character areas in the Para Character areas included as suggested. KNP07 Character parish: Picton houses and Park Lane: should these change Pictures and descriptions included. Areas be more defined? e.g. Picton houses on Stevenage Road and Oakfields Road and Park Lane (east of A1(M))
KBEF5 Views and 9.6.3 67 View south east from Oakfields Road and Avenue Para Appropriate siting of proposed school KNP07 Character - junction: protection of this view seems to conflict change facilities can help to maintain this view. Areas with policy KB4 to develop site 58 for a secondary school and possibly provide a main or secondary access point from this junction.
KBEF5 Views and 9.6.3 67 Figure 45 Aveune should be spelt Avenue in the Para Amended as suggested. KNP23 Character . caption change Areas
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBEF5 Views and 9.6.8 70 A rare example……by Lutyens in seen in its green Para Amended as suggested. KNP07 Character setting. Change to ‘is’ seen. change Areas
KBEF5 Views and 9.6.1 71 This text only refers to Stevenage Road. It should Para Amended as suggested. KNP07 Character 1 also include mention of the Picton Houses on change Areas Oakfields Road as per the hatched Character Area 1 shown on Policies Map Shaded Area.
KBEF5 Views and Fig 72 This photo does not show variation in design Para Amended as suggested. KNP07 Character 53 between Picton Houses. Would be good to have an change Areas additional photo to show Oakfields Road.
KBEF5 Views and Fig 72 This photo does not show the Para Not intended to. The view is of one of the KNP07 Character 54 architecture/character of Picton Houses as the change approaches into Knebworth Areas houses are not visible.
KBEF5 Views and 9.6.1 73 Add ‘(east of A1(M))’ to heading Para Amended as suggested. KNP07 Character 2 change Areas
KBEF5 Views and 9.6. 74 Trinity Church is the Register of Buildings of Local Para Amended as suggested. KNP23 Character Interest (NHDC, 2008). It should be Trinity Church change Areas is listed in the Register of Buildings of Local Interest (NHDC, 2008).
KBEF6 Non- 9.8 76 KBEF6 (Heritage assets) – This section is designed Para All reference to the silo has been KNP03 Designated to protect certain key local buildings. It provides change removed from the KNP. Heritage protection to all of those buildings that are listed on Responsibility for removal from the Assets the Knebworth Register of Buildings of Local Knebworth Register of Buildings of Local Interest. The brick silo at Swangleys Farm is Interest lies elsewhere and is, we believe, included in that register and is therefore covered in progress. under KBEF6. However we received an email from
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. the Neighbourhood Plan team in March 2019 advising that – due to the poor condition of the tower and the anticipated need to demolish it – that the KNP team “concluded that we will remove the proposed designation of the tower from the plan going forwards”.
KBEF6 Non- 9.8 76 record breaking should be record-breaking Para Wording removed KNP23 Designated change Heritage Assets
KBEF6 9.8 76 We would therefore strongly recommend that the Para Sub-section '9.7.1 Archaeological and HCC wording of policy KBEF6 be amended to provide for change below ground remains' added. known and as yet unknown below ground archaeological remains within the parish, or alternatively that a new policy be added to accomplish the same.
KBT1 Sustainable 10 78 Policies KBT1, KBT2, KBT3, KBT4 and KBT5 Para Setting up a CPRE Modes of One of the obvious problems for the village is how Change Placemaking/MasterPlanning Group has Travel both the East-Coast Mainline railway and Stevenage been added to the Action Plan. – London Road B197 divide and frustrate the ease of movement across the village. The plan identifies KBT1 and KBT2 are intended to address the need to address the three pinch points beneath the car dependency problem. and over the railway line and includes an idea to extend an underpass at Knebworth Station. To overcome these barriers the place-making group will be a good forum, thinking ‘outside the box’, to develop long term ideas to then be addressed with the relative planning, highways and transport bodies Car dependency – the allocated new housing areas
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. are not only far too large and encroaching the countryside, but likely by location to be car dependent. It is crucial that these new developments should hit sustainable travel targets and support an overall shift in travel in the village.
KBT1 Introduction 10.1 78 It states ‘pedestrians and cyclists are not well Para Text accompanying the Policy KBI1 has KNP23 catered for.’ It should also include accessibility for change been amended. the disabled or less mobile.
KBT1 Sustainable 10.2 79 Policy KBT1 - Sustainable modes of Travel The text following Policy KBT1 includes HCC Modes of Opportunity to promote cycling if a safe link could 'safe link …to join up with the segregated Travel be provided to join up with the segregated cycle cycle network in Stevenage and with the network in Stevenage and with national cycle route National Cycle Route 12' and the Action 12 which currently passes to the West of the village. Plan item 10. Consideration needs to be given to the policy to Whilst noting the draft NC GTP, the HCC provide a have a more robust link to LTP4 user LTP4's Objective 5 is to enhance the hierarchy. quality and vitality of town centres, The draft NC GTP recognises the importance of therefore the B197 through the 'High providing an integrated cycle network with the Street' should be dealt with in a balanced development of a sustainable transport corridor Para way. along the B197 (SM93) and the need for the change The word 'may' in the second sentence of provision of cycling and walking routes from 5th paragraph of justification of KBT1 developments to existing cycle routes and the B197 changed to 'should'. corridor (SM94). Text on pages 79 and 83 changed from Page 79 –It is suggested that wording is 'Hertfordshire County Council Travel strengthened from ‘A switch to walking and cycling Plan' to 'Hertfordshire County Council may be encouraged by improving the safety and Local Transport Plan 4 (2018-2031)'. quality of existing routes and facilities, to ‘A switch to walking and cycling should be encouraged by improving the safety and quality of existing routes and facilities. Pages 79 and 83 makes a reference to Hertfordshire
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. County Council Travel Plan (HCC, 2018) regarding predicted car trips increasing by 17-18% across the county, this reference should be made Local Transport Plan 4 (2018-2031).
KBT5 Bus Routes 10.6 84 There have been recent changes to the bus services Para The text following KBT5 has been altered KNP07 para – the 300 service no longer runs through change to suggest that Route 44/45 is diverted 1 Knebworth. and if possible enhanced, rather than Route 301
Appen- Appendix A 86 Policies Map - Would it be possible to show Para Views map now has view directions KNP07 dix directional arrows for the Protected Views. Change restored
Appen- Appendix A 86 Below the main map, it should say Para Agreed - amend policy map 1. with this KNP23 dix “The shaded area is expanded on the following Change wording. ButThere is no intention that page.” wording beneath the shaded area be The shading could be lightened so that it is easier to readable, I have also been asked to make read the text beneath it. it more opaque..
Appen- Appendix A 87 Policies Map - Would it be possible to show Para Views map now has view directions KNP07 dix directional arrows for the Protected Views. Change restored
Appen- Appendix A 87 Policies Map - The eastern purple hatched Para All now consistent KNP07 dix Character Area 1 covers both Stevenage Road and Change Oakfields Road although Oakfields Road is not mentioned in the definition of Character Area 1: Picton Houses in Policy KBEF5 on page 64.
Appen- Appendix B, K 89 Add ‘e.g.’ before underground parking as per Para Example has been removed from KNP07 dix wording on page 27. It is only one example. Also see Change Objective pages 27 and 53. Wording should be consistent each time the objective is mentioned.
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
Appen- Appendix E 95 Abbreviations and Glossary Para 'HMO' added to Glossary KNP20 dix If HMOs are to be mentioned in the Plan then HMO change must be included in this area.
Appen- Appendix E 95 We still have Objectives that are part of the action Para All revised KNP23 dix Plan. E.g. N and P. These have policy references but change do the descriptions actually reflect this?
Appen- Appendix G 101 This refers to Rusling End. It is usually ‘Rustling Para Amended as suggested. KNP23 dix End’ – the rest of the document uses this spelling. change
Appen- Appendix H 106 Final entry should be ‘Woodland Trust’ Para Amended as suggested KNP23 dix change
KBEF1 Biodiversity 9.2 54 Herts Ecology is broadly in agreement with the Para & Policy KBEF1 reworded to promote nett HCC following Policy; however we suggest removal of Policy gain, rather than prevent nett loss. red text and addition of green text, excluding the The text following Policy KBEF1 has been explanatory text in square brackets: changed as proposed by HCC. KBEF1 Biodiversity Also in the text, added reference to Knebworth’s rich natural heritage includes Natural England biodiversity calculator Knebworth Woods Site of Special Scientific Interest and that it (or independent equivalent) (SSSI), eight Ancient Woodlands and 20 Local should be prior to major development to Wildlife Sites, listed in an Appendix G to the plan. provide a baseline for future comparison. In order to ensure no net loss of biodiversity and improve biodiversity overall, all developments must: a. wherever possible, retain existing trees, hedgerows and green road borders to minimize disruption to wildlife, and b. preserve existing and propose new wildlife corridors and habitats, in accordance with HERC recommendations [remove as unnecessary] c. reduce or eliminate gaps in existing corridors by
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Policy Policy Name Para Page Comment Summary Action Change Required Ref. diverse planting d. create new corridors within developments to reduce built ‘mass’, enhance wildlife diversity and to increase surface water retention. Some should connect with new small wooded areas (see Further Ambition proposals). Additional guidance provided by Hertfordshire Ecology and [add, as Herts Ecology are the funded ecological advisers to NHDC] Hertfordshire and Middlesex Wildlife Trust, including appropriate use of a biodiversity calculator, should be taken into account when assessing the ecological merits of planning applications.
KBEF1 Biodiversity 9.2 54 Consideration should be given to simplifying the Para & Policy KBEF1 Reworded NHDC policy by removing the explanatory text in the first Policy and last sentences. Is it intended that this policy should be used when considering all types of development, including house extensions or conversions?
KBBE2 Sustainable 6.3 29 There is reference to a ‘separate document’ on Para & Reference provided. KNP07 Buildings Knebworth Parish Council’s website. Full details App should be provided. change
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Policy Policy Name Para Page Comment Summary Action Change Required Ref.
KBBE4 Design 6.5 30 We would also suggest recommending new Para & Building in Context' reference added to HE developments use the ‘Building in Context’ toolkit App KBBE3 - Accessibility and adaptability to develop their designs. change
KBEF1 Biodiversity 9.2.4 58 The reference to Action Oad should be Action Oak Para & Amended as suggested. KNP23 . (and in Bibliography) App change
KBEF6 Non- 9.8 76 We would note, however, that information Reference changed to HE Designated regarding designated heritage assets - and https://historicengland.org.uk/listing Para & Heritage particularly any listed buildings, scheduled App Assets monuments and registered parks and gardens, change should be derived from the National Heritage List, rather than third party websites.
KBEF6 Non- 9.8 76 We would also highlight that Knebworth House is Wording change to II* listing. HE Designated listed at Grade II*, which puts it in the top 5.8% of Heritage historic buildings in the country. At present the plan Para & Assets identifies it as Grade II (Figure 59). The national App heritage list can be accessed via Historic England’s change website, here:
KBW3 Recreational 7.4 45 Any 'Tax' on developers will reduce the chance of Para Action Plan and Community Priority List KNP24 Green Spaces affordable housing change updated to show what S106/CIL funds would be needed for.
Object Objectives 3.3 18 Objective K - Consideration should be given to Text deleted as suggested. NHDC Objective deleting the text in brackets as the objective is clear Change without this additional explanatory text.
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Appendix Q Action Plan Revised Action Plan
No. Project / Task Timetable Project Lead Effect of non- Outcome sought / implementation Objective
Built Environment
1 Obtain (free) off-street parking Ongoing PC to liaise with NHDC. Limited growth of Increased use of village for shoppers in St. Martin’s Consider for Section trade for retail shops and other services. Road car park. 106 of CIL funding. businesses
2 Install electric vehicle charging Ongoing PC through funding Slower change from Make the use of electric points at PC ‘owned’ sites, e.g. from developers, fossil fuel vehicles. vehicles by local Village Hall car park, Watton electric car residents more viable Road Recreation Ground. manufacturers etc. and attractive
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No. Project / Task Timetable Project Lead Effect of non- Outcome sought / implementation Objective
3 Set up a Place-making Action To be in place Neighbourhood Plan Unimaginative, Influence urban design to Group for when the Steering Group standard estate strengthen the first major establish a group to layouts. connection between housing comment on people and the places development development proposals they share. Obtain public planning spaces within application is developments that are made. the heart of the community.
Wellbeing
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No. Project / Task Timetable Project Lead Effect of non- Outcome sought / implementation Objective
4 Actively seek to obtain a new PC through appropriate Unlikely to attract Have modern and indoor and outdoor sports hub, funding bodies. more residents to attractive sports facilities to include an all-weather pitch, Knebworth Football participate in healthy that allow local sports new pavilion, changing rooms sports activities. clubs to develop and is Club is offering active and social facilities liaison with KPC to Continued travel by available to the general car to alternative develop new sports community. facilities or improve sports facilities for
existing ones. Some practice and playing funding available. sessions. Consider for Section 106/CIL funding.
5 Have a minimum of 1.5 Ha of Ongoing In the event of the Loss of opportunity for Provide for current land that can be used for current privately residents of flats and demand for allotments. allotments. owned allotments houses with small closing the PC seek gardens to grow their
provision of suitable own fresh produce. land from future developers across all sites.
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No. Project / Task Timetable Project Lead Effect of non- Outcome sought / implementation Objective
6 To lobby for additional G P’s Ongoing Request Knebworth Longer waiting times Have sufficient medical and health professionals based and Marymead Medical to see a health staff to provide an in the village Practice Patient professional with a acceptable service that Participation Group to likely increase in visits meets current needs of
raise with relevant to Hospital A and E the area and the future Health Authorities departments. needs of a 30% increase in population.
7 Improve the Scout and Guide Asap Volunteers with PC Further deterioration Improved facilities that hut in Gun Lane guidance. Consider for of buildings, becoming are attractive and cater Section 106 or CIL unsuitable for use. for expected increase in funding. young people from expanded village joining.
Environment and Flooding
8 Create community woodland Asap Establish Volunteer Steady loss of Improve the local areas Trust. Consider for accessible woodland. environment and wildlife Section 106 or CIL habitat. funding
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No. Project / Task Timetable Project Lead Effect of non- Outcome sought / implementation Objective
Traffic, Transport and Parking
9 Obtain disabled access to Ongoing PC and user groups to Continued Easy access to trains for station platforms lobby rail service inaccessibility of all residents platforms for many providers Get the parking tariff people with reduced updated to say that
mobility, and disabled parking is free continued access in all locations provided problems for parents blue badge is displayed. and carers with children in prams and pushchairs.
10 Implement a solution to the Ongoing. PC to liaise with HCC Continued conflict A safer and less ‘High Street’ traffic and parking and NHDC. Set up a between through congested High Street problems volunteer working traffic, parked vehicles that is attractive to group to consider and pedestrians with shoppers innovative solutions its negative effect. and advise PC. Consider for Section 106 or CIL funding.
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No. Project / Task Timetable Project Lead Effect of non- Outcome sought / implementation Objective
11 Obtain segregated cycle route Asap. PC to liaise with HCC as Many cyclists will not Provide safer cycling and between Knebworth and cycle between encourage more cycle Highways Authority. Stevenage cycleway network. May be provided as Knebworth and trips. Stevenage because of part of draft HCC North Central Growth and potentially dangerous, sub-standard un- Transport Plan. segregated cycle on unrestricted hill section of B197.
12 Obtain land for off-street Before the PC to liaise with Increased conflict To reduce the adverse parking for rail commuters completion of landowners and major between residents and effect of increased rail major housing developers. Consider rail commuters for on- commuter parking
developments in for Section 106 or CIL street parking space expected with the neighbouring funding. development of villages (e.g. Knebworth and Codicote and surrounding villages. Woolmer Green) and in Knebworth.
13 Obtain an extension of the rail Before the PC to lobby rail Continued safety Motor traffic free link for station foot access tunnel to completion of companies issues for pedestrians pedestrians between Kerr Close major housing using the sub-standard western and eastern developments in footway under the parts of the village. the west of railway bridge. Knebworth
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No. Project / Task Timetable Project Lead Effect of non- Outcome sought / implementation Objective
14 Obtain extra capacity on rail Ongoing Request Knebworth Overcrowded Improved capacity on rail services stopping at Rail User’s Forum carriages over longer services to cater for the Knebworth public group to lobby peak periods. expected increase in rail service operators. demand.
15 Obtain additional eastbound To be introduced KPC to liaise with Herts More rail commuter Encourage rail services (through Codicote, before the CC, NHDC and the bus parking demand in the commuters to use the bus and Old Knebworth and completion of service provider. roads around in preference to private passing Knebworth Station) in the major Consider for Section Knebworth Station car to access Knebworth the morning rail commuting housing 106 or CIL funding. Station peak period and in reverse developments during evening peak rail proposed for commuting period Codicote and the western side of Knebworth village.
16 Widen footway under Station To be in place KPC to liaise with HCC Worsening of Improved safety for road Road rail bridge with prior to the as Highways Authority. unsatisfactory, users, particularly appropriate traffic occupation of Consider for Section potentially dangerous pedestrians and cyclists management scheme, e.g. KB1 or KB2 106 or CIL funding. conditions for alternate flow signal control. pedestrians and cyclists.
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No. Project / Task Timetable Project Lead Effect of non- Outcome sought / implementation Objective
17 Widen footway under Gun To be in place KPC to liaise with HCC Worsening of Improved safety for road Lane rail bridge with prior to the as Highways Authority. unsatisfactory, users, particularly appropriate traffic occupation of Consider for Section potentially dangerous pedestrians and cyclists. management scheme. KB1 and KB2 106 or CIL funding. conditions for pedestrians and cyclists.
18 Improve pedestrian and cycle To be in place KPC to liaise with HCC Worsening of Improved safety for road facilities at Stevenage prior to the as Highways Authority. unsatisfactory, users, particularly Road/Watton Road/ Station occupation of Consider for Section potentially dangerous pedestrians and cyclists Road/ London Road junction KB1, KB2 or KB4 106 or CIL funding. conditions for pedestrians and
cyclists.
19 Improve layout of London To be in place KPC to liaise with HCC Worsening of Improved safety for road Road/Swangley’s Lane prior to the as Highways Authority. unsatisfactory, users, particularly junction and the access to occupation of Consider for Section potentially dangerous pedestrians and cyclists Primary School KB1, KB2 or KB4 106 funding. conditions for pedestrians and cyclists.
20 Use part of the parking area off Particularly PC to liaise with Continued level of on- To provide more off- Kerr Close for rail commuter useful if rail Knebworth Village street rail commuter street long term parking parking station foot Trust regarding the parking. for the expected increase access tunnel lease in rail commuters extended.
Basic Conditions Statement Page: 132 of 134 Date: 12 Mar 2021
No. Project / Task Timetable Project Lead Effect of non- Outcome sought / implementation Objective
27.09.20
Basic Conditions Statement Page: 133 of 134 Date: 12 Mar 2021