FM 010

MM 010 / FM 039 32 Policy SP2 Policy SP2: Settlement Hierarchy and Spatial Distribution. Between 2011 and 2031, the plan makes provision for at least 13,000 new homes. Approximately 80% The majority of the District’s housing development and the substantial majority of new employment, retail and other development will be located within the adjusted settlement boundaries of or adjoining the following towns: • Baldock (2,198 homes) • Hitchin (1,842) • Letchworth Garden City (1,928) • Royston (1,899) • Stevenage (including Great Ashby)32 (1,705); and • Luton32 (1,485) Approximately 13% of housing, along with supporting infrastructure and facilities will be delivered within the adjusted settlement boundaries of the following five villages for the levels of development indicated: • Barkway (208) • Knebworth (731) To ensure the plan is positively prepared, justified, effective and consistent with national policy following the Matter 21 to 26 hearings as supported by the statements to those sessions and documents including ED161, ED172, ED191A and ED191B Note: Indicated figures for the five villages are 9 Ref. Page (LP1) Policy / Paragraph Modification Reason / source for Further Modification • Codicote (363) • Ickleford (235) • Little Wymondley (312) The remaining development will be dispersed across the District as set out below… [Remainder of proposed Policy SP2 incorporating MM010 unchanged] for development within the adjusted settlement boundary and will not be the same as the figures presented in Chapter 13 which are for the whole parish.
Making Little Wymondley is classed a Category A one of five villages where a greater amount of development has been allocated, is not sustainable, there is no justification for the allocation of 331 houses in Little Wymondley (WY1). The proposal/modification is unsustainable and there are no special circumstances for the development.

Thank you for consulting Transport for London (TfL). I can confirm that we have no comments to make on the further proposed main modifications.

I have one general point which is that the proposals take no cognisance of the changes in behaviour that are arising as a result of the Covid 19 pandemic. I appreciate that specific plans may have to wait for the next review but the current proposals should at least recognise that changes of behaviour may result in opportunities as well as challenges. For example, there is much insistence in the proposals on the provision of retail space but it needs to be recognised that more shopping is being done online and we may actually need less retail space. The opportunity then arises to re-purpose redundant retail space to meet housing needs. Then the issue will become one of ensuring that decent housing standards are met for any shops converted to dwellings.

I have mentioned shops specifically but the same argument applies to surplus office accommodation where more work is being done from home. Again, offices could in some circumstances be converted into flats.

As a local resident (central Letchworth) I am writing to object to the local housing plan.

The ONS estimates that North Herts requires a maximum of 6,000 new homes, so a plan that will deliver 3 times that amount, predominantly built on Green Belt land that acts as the lungs for the country, is both environmentally and economically damaging

I urge you to reconsider and scale back the plans to that which is actually needed.

I am emailing to register my strong opposition to the current NHDC Local Plan. The figure of13,000 new homes in the district is well over twice the requirement estimated by the ONS. That 85% of these are to be located on green belt is even more concerning. As it stands, the Plan appears little more than a charter for greedy landowners and opportunistic developers, at the end of which there will still be insufficient genuinely affordable homes, increased congestion on the District`s roads and permanent loss of attractive countryside.

I am writing to you with reference to BK3 planning application, and the North Hertfordshire Local Plan, to express my concerns about the transparency of the planning and planning review process.

Having received yet another letter from the parish council, following the latest update which shared the request from NHDC to the inspector to remove BK3 from the Local Plan, I now understand that BK3 is still in the plan.

There has been no public correspondence published on the discussion between the Inspector and NHDC on the Draft Schedule of Further Modifications, and no reason published on the Inspector's decision not to remove BK3 from the Local Plan. We have not had a fair or proportionate opportunity to put our collective case against the inclusion of BK3 in the local plan.

Further, there has been a fundamental failure from the beginning on behalf of the developer to engage with the community on the planning process. I am dismayed to have to write to yet again to share concerns in what feels like a drawn out, non transparent and undemocratic process.

Just to reiterate my specific concerns,

- No sustainable transport plan, significant concerns about the volume of traffic that will go down Barkway Road. Particular bottleneck in Royston. As a cyclist, particular concerns about the lack of viable options to either use public transport (no bike friendly bus service), or safely cycle to longer distance public transport option via the Barkway to Royston road. Entirely unclear how this aligns with the governments new plans to reduce carbon emissions in the short term. Aside from public transport concerns, there are not even plans to add in public charging points for electric vehicles.

- NHDC will normally permit development proposals if: The site lies within the main area of the village; and the proposal would maintain or enhance the character or visual quality of the village. NHDC were seeking to move the permitted development boundary of the village to include BK3 without prior consultation with the surrounding area. NHDC are now thankfully requesting BK3 be removed, but we now have the latest twist with this issue of lack of transparency between the NHDC and Inspector.

- Impact on the environment - the proposed site sits on the Chiltern Ridge, in a historic coaching village. New development would not form part of the village, impact on character

- Almost comical lack of local services in the village to support such an increased development. Pub that only serves beer, no shop, small school, inevitable Increased traffic to Barley and Royston (all via road) as a result.

Copying local elected representatives to flag my concerns about lack of transparency and poor governance on this critical planning process.

I seriously object to the development plans of NHDC to build on green belt land in and around Hitchin and other surrounding villages.
There are sufficient unfulfilled planning consents available to meet Office of National Statistics development numbers of up to 6000, and adequate failed commercial sites to meet this need by redevelopment.

I wish to raise my concerns of the North Herts District Council (NHDC) Local Plan.

In particular I am very disappointed that the number of new houses proposed is growing in a plan that has been changed many times and therefore indicates that the planners are unsure of what they are trying to achieve. The current number of new houses, 18,500, is way above the number that the Office of National Statistics confirm as being needed namely 3,500 - 6,000.

On top of this most of the developments are planned to be built on Green Belt land which is supposed to be protected. We are currently experiencing a pandemic that has led people to get back to nature and the number of walks in the beautiful countryside in North Herts has increased significantly. Local people have come to appreciate the local countryside more and need these green spaces for their physical and mental health. There are many 'brown field' sites available that should first be used for building houses particular on the west side of Stevenage.

In addition, what thought has been given of the impact approx 50 - 60,000 people living in those homes will have on the local environment in terms of water supply, communications, additional roads, schools, bus services, health services etc.

Lets be sensible and manage expectations, do we really need to build 3 times the number of houses confirmed and destroy not only our green belt land but the wildlife and pleasure that so many people enjoy in our countryside.

I was alarmed to see that the site BK3 remains in the plan.

Discussions between the Parish Council and the planners at NHDC concluded that BK3 and with it the status of Barkway as a ‘village for growth’ should be removed from the plan. NHDC advised the inspector in 2020 that this should be acted upon and the status of Barkway and the BK3 site should be deleted from the plan.

There is no transparency on this matter. No public correspondence, just an assertion that the Inspector has agreed to the schedule of Further Modifications.

There are no reasons given for the Inspector’s decision not to accept NHDC’s request.

Doing this without disclosing a reason is unacceptable.

We, as a village represented by the Parish Council, have not had a fair opportunity to put our case against the inclusion of BK3. We support NHDC’s request to remove it.

There are other issues:

Ref ED175. Enlarging BK3 to include HCC’s school site is unacceptable. HCC have not requested this. This decision to include it gives rise to the risk of yet more unacceptable housing being built.

Ref MM010/FM039 and MM217/FM113 relate to housing applications and permissions. The number of 208 has been quoted but is without any explanation; again a lack of transparency. Similarly, the table shown in MM217/FM113 is incorrect. The Parish Council have told you separately why. Both these points have to be transparently explained.

Ref MM215/FM111 and MM216/FM112 and MM219/FM114 are also incorrect in a number of details. There are no S106 contributions to come from Barley as they have no significant developments. Any contribution from Barkway in relation to this cannot be matched by Barley and in essence, especially as school transport is already provided, Barkway S106 money would benefit Barley residents. Unacceptable. I suggest all three are deleted.

We strongly object to the North Herts DC local plans proposed development of 2100 homes East of Luton, required solely to meet an unmet need from Luton of 9300 homes calculated in 2017 as argued in ED224, for the following reasons;-

1. Valuable Green Belt land, there are no adequate exceptional circumstances
2. Luton’s house building is much higher than 2017 forecast, updated assessed needs are lower, unmet needs reduced to around 2000
3. Luton’s unmet needs have already been more than covered by Central Beds as the designated ‘best fit’ neighbour; with many already in build
4. Luton’s failure to require adequate family housing from developers

Furthermore, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures.

See Attached

See Attached

See Attached

See attached

See Attached

I wish to express my strong objection to Barkway BK3 being included in the local plan especially after NHDC requested that it be excluded. My concerns / objections are as follows:

1. NHDC requested that BK3 be excluded but this request has not been accepted. The process has been far from transparent - and this seems to be a disagreement between professionals that will have a huge effect on a small village

All correspondence between the inspector and NHDC on the Draft Schedule of Further Modifications relating to BK3 must be published.

Please treat this as a request under the Freedom of Information Act 2000 for this information to be disclosed.

2. Those who object to the suitability of BK3 must be given a chance to put their case once the above has been published.

3. Examination document ED175. HCC have not requested that the school site be included in housing allocation site BK3. The land is not required for a school and should not be part of the housing site. As such BK3 is not a suitable site as it is not connected with the rest of the village.

4. There are several material mistakes in the published documentation - these alone require a review of the decision. For example the tables showing new homes for the parish in MM217/FM113 do not agree / are wrong and include double counting. Another example relates to the S106 contributions where it proposes spending the money for the benefit of Barley (MM219/FM114 paragraph 13.39, MM216/FM112 in relation to BK3, MM215/FM111 in relation to BK2). It is wrong to suggest taking S106 contributions from a village that has a huge new housing development and spending it for the benefit of another village which does not have any proposed developments.

Clearly if decisions have been made on incorrect facts and assumptions the decision needs to be reviewed. Once we have access to the correspondence between the inspector and NHDC there may be further errors uncovered requiring further review.

My reasons for objection to the NHDC Local Plan are:
Lack of transparency in the process
Unapproved enlargement of site BK3 to include Herts County Council owned land
Lack of detail or explanation on numbers of housing requirements
Proposal of S106 contributions from developments being shared unfairly with Barley

I object to the Further Main Modifications to the North Hertfordshire Local Plan 2011 - 2031 (the Plan), May 2021.

My objection comes from the lack of transparency to several Further Modifications, including housing numbers for Barkway and contributions from development in Barkway towards sustainable travel to school. I also object to the justification for the integration of the Reserve School Site into BK3; and the lack of transparency in the process that has denied the Parish Council the opportunity to support the removal of BK3 from the Plan as requested by North Hertfordshire District Council (NHDC), or to object to a Further Modification not to remove BK3 from the Plan

I object to parts or the whole of the content of the following Further Modifications, including aspects of the justification put forward to support them.
MM010/FM039, p.32, Policy SP2, Settlement Hierarchy and Spatial Distribution
MM012/FM041, p.33, New paragraph after paragraph 4.12
MM217/FM113, p.144, Table after Policy BK3
MM215/FM111, p.144, Policy BK2
MM216/FM112, p.144, Policy BK3
MM219/FM114, p.144, Paragraph 13.39

I also object to the following Examination Documents which have been submitted to the Examination between November 2019 and March 2021:
ED170 Council's further response to Inspector’s Letter of 9 August (EX168)
ED 175 Council’s response to Inspector 9 July 2019

Finally, I object to the lack of transparency over this most recent part of the Examination process that has not provided the opportunity for the Parish Council to fairly state its case in relation to BK3, and the omission of a Further Modification refusing NHDC’s request to exclude BK3 from their Local Plan.

My reasons for objection to the NHDC Local Plan are:
Lack of transparency in the process
Unapproved enlargement of site BK3 to include Herts County Council owned land
Lack of detail or explanation on numbers of housing requirements
Proposal of S106 contributions from developments being shared unfairly with Barley

I object to the Further Main Modifications to the North Hertfordshire Local Plan 2011 - 2031 (the Plan), May 2021.

My objection comes from the lack of transparency to several Further Modifications, including housing numbers for Barkway and contributions from development in Barkway towards sustainable travel to school. I also object to the justification for the integration of the Reserve School Site into BK3; and the lack of transparency in the process that has denied the Parish Council the opportunity to support the removal of BK3 from the Plan as requested by North Hertfordshire District Council (NHDC), or to object to a Further Modification not to remove BK3 from the Plan

I object to parts or the whole of the content of the following Further Modifications, including aspects of the justification put forward to support them.
MM010/FM039, p.32, Policy SP2, Settlement Hierarchy and Spatial Distribution
MM012/FM041, p.33, New paragraph after paragraph 4.12
MM217/FM113, p.144, Table after Policy BK3
MM215/FM111, p.144, Policy BK2
MM216/FM112, p.144, Policy BK3
MM219/FM114, p.144, Paragraph 13.39

I also object to the following Examination Documents which have been submitted to the Examination between November 2019 and March 2021:
ED170 Council's further response to Inspector’s Letter of 9 August (EX168)
ED 175 Council’s response to Inspector 9 July 2019

Finally, I object to the lack of transparency over this most recent part of the Examination process that has not provided the opportunity for the Parish Council to fairly state its case in relation to BK3, and the omission of a Further Modification refusing NHDC’s request to exclude BK3 from their Local Plan.

My reasons for objection to the NHDC Local Plan are:
Lack of transparency in the process
Unapproved enlargement of site BK3 to include Herts County Council owned land
Lack of detail or explanation on numbers of housing requirements
Proposal of S106 contributions from developments being shared unfairly with Barley

I object to the Further Main Modifications to the North Hertfordshire Local Plan 2011 - 2031 (the Plan), May 2021.

My objection comes from the lack of transparency to several Further Modifications, including housing numbers for Barkway and contributions from development in Barkway towards sustainable travel to school. I also object to the justification for the integration of the Reserve School Site into BK3; and the lack of transparency in the process that has denied the Parish Council the opportunity to support the removal of BK3 from the Plan as requested by North Hertfordshire District Council (NHDC), or to object to a Further Modification not to remove BK3 from the Plan

I object to parts or the whole of the content of the following Further Modifications, including aspects of the justification put forward to support them.
MM010/FM039, p.32, Policy SP2, Settlement Hierarchy and Spatial Distribution
MM012/FM041, p.33, New paragraph after paragraph 4.12
MM217/FM113, p.144, Table after Policy BK3
MM215/FM111, p.144, Policy BK2
MM216/FM112, p.144, Policy BK3
MM219/FM114, p.144, Paragraph 13.39

I also object to the following Examination Documents which have been submitted to the Examination between November 2019 and March 2021:
ED170 Council's further response to Inspector’s Letter of 9 August (EX168)
ED 175 Council’s response to Inspector 9 July 2019

Finally, I object to the lack of transparency over this most recent part of the Examination process that has not provided the opportunity for the Parish Council to fairly state its case in relation to BK3, and the omission of a Further Modification refusing NHDC’s request to exclude BK3 from their Local Plan.

My reasons for objection to the NHDC Local Plan are:
Lack of transparency in the process
Unapproved enlargement of site BK3 to include Herts County Council owned land
Lack of detail or explanation on numbers of housing requirements
Proposal of S106 contributions from developments being shared unfairly with Barley

I object to the Further Main Modifications to the North Hertfordshire Local Plan 2011 - 2031 (the Plan), May 2021.

My objection comes from the lack of transparency to several Further Modifications, including housing numbers for Barkway and contributions from development in Barkway towards sustainable travel to school. I also object to the justification for the integration of the Reserve School Site into BK3; and the lack of transparency in the process that has denied the Parish Council the opportunity to support the removal of BK3 from the Plan as requested by North Hertfordshire District Council (NHDC), or to object to a Further Modification not to remove BK3 from the Plan

I object to parts or the whole of the content of the following Further Modifications, including aspects of the justification put forward to support them.
MM010/FM039, p.32, Policy SP2, Settlement Hierarchy and Spatial Distribution
MM012/FM041, p.33, New paragraph after paragraph 4.12
MM217/FM113, p.144, Table after Policy BK3
MM215/FM111, p.144, Policy BK2
MM216/FM112, p.144, Policy BK3
MM219/FM114, p.144, Paragraph 13.39

I also object to the following Examination Documents which have been submitted to the Examination between November 2019 and March 2021:
ED170 Council's further response to Inspector’s Letter of 9 August (EX168)
ED 175 Council’s response to Inspector 9 July 2019

Finally, I object to the lack of transparency over this most recent part of the Examination process that has not provided the opportunity for the Parish Council to fairly state its case in relation to BK3, and the omission of a Further Modification refusing NHDC’s request to exclude BK3 from their Local Plan.

See Attached

See Attached

Please see below my objections regarding the above:

1. Transparency of the Process

• There has been no public correspondence between the Inspector and NHDC on the Draft Schedule of Further Modifications, only NHDC’s assertion that the Inspector has agreed the Schedule of Further Modifications.
• The reasons for the Inspector’s decision not to accept NHDC’s request to exclude BK3 from the Local Plan has not been published.
• We have not had a fair or proportionate opportunity to put our case against the inclusion of Site BK3. We support NHDC’s request to remove site BK3 from their Local Plan.

2. Enlarging BK3 to Include Hertfordshire Country Council’s (HCC) School Site

Examination Document ED175. This document says that including the school site in the housing allocation site BK3 is pragmatic. HCC have not requested this amendment. This decision may be practical for NHDC but if BK3 includes HCCs land, then there is a risk that more homes than the 140 allocated will be built on this site. The land is not required by HCC for a school. The HCC school site should not be part of housing site BK3.

3. Figures for Housing Allocations, Completions, and Permissions

MM010/FM039 says the number of homes expected to be delivered in Barkway village in the Local Plan period is 208. There is no evidence given for this figure. The figure is critical because Barkway is identified as suitable to support higher levels of housing that Category A villages on the basis that the number of homes expected to be delivered is ‘more than 200’. The figures need to be justified.

MM217/FM113 is a table showing new homes for the parish. The table is wrong and the figures need to be justified.

4. S106 Contributions to Provide School Transport

The contribution from construction of new homes in Barkway is mentioned three times in the Schedule of Further Proposed Main Modifications. School transport is already provided, and BPC have been consulted on how S106 money should be spent for the benefit of the parish. If this modification was to remain in the Local Plan for a bus service between Barkway and Barley schools, Barley would be benefiting from development in Barkway.

MM215/FM111 (in relation to Policy BK2): “Contribution towards travel by sustainable modes of transport between Barley and Barkway schools”. We suggest this is deleted.

MM216/FM112 (in relation to Policy BK3): “Contribution towards travel by sustainable modes of transport between Barley and Barkway schools.” We suggest this is deleted.

MM219/FM114 (in relation to Paragraph 13.39): “Contributions to support sustainable travel between the two sites should be secured from new developments.” There are no developments proposed in Barley, only in Barkway and we suggest this is deleted.

Please see below my objections regarding the above:

1. Transparency of the Process

• There has been no public correspondence between the Inspector and NHDC on the Draft Schedule of Further Modifications, only NHDC’s assertion that the Inspector has agreed the Schedule of Further Modifications.
• The reasons for the Inspector’s decision not to accept NHDC’s request to exclude BK3 from the Local Plan has not been published.
• We have not had a fair or proportionate opportunity to put our case against the inclusion of Site BK3. We support NHDC’s request to remove site BK3 from their Local Plan.

2. Enlarging BK3 to Include Hertfordshire Country Council’s (HCC) School Site

Examination Document ED175. This document says that including the school site in the housing allocation site BK3 is pragmatic. HCC have not requested this amendment. This decision may be practical for NHDC but if BK3 includes HCCs land, then there is a risk that more homes than the 140 allocated will be built on this site. The land is not required by HCC for a school. The HCC school site should not be part of housing site BK3.

3. Figures for Housing Allocations, Completions, and Permissions

MM010/FM039 says the number of homes expected to be delivered in Barkway village in the Local Plan period is 208. There is no evidence given for this figure. The figure is critical because Barkway is identified as suitable to support higher levels of housing that Category A villages on the basis that the number of homes expected to be delivered is ‘more than 200’. The figures need to be justified.

MM217/FM113 is a table showing new homes for the parish. The table is wrong and the figures need to be justified.

4. S106 Contributions to Provide School Transport

The contribution from construction of new homes in Barkway is mentioned three times in the Schedule of Further Proposed Main Modifications. School transport is already provided, and BPC have been consulted on how S106 money should be spent for the benefit of the parish. If this modification was to remain in the Local Plan for a bus service between Barkway and Barley schools, Barley would be benefiting from development in Barkway.

MM215/FM111 (in relation to Policy BK2): “Contribution towards travel by sustainable modes of transport between Barley and Barkway schools”. We suggest this is deleted.

MM216/FM112 (in relation to Policy BK3): “Contribution towards travel by sustainable modes of transport between Barley and Barkway schools.” We suggest this is deleted.

MM219/FM114 (in relation to Paragraph 13.39): “Contributions to support sustainable travel between the two sites should be secured from new developments.” There are no developments proposed in Barley, only in Barkway and we suggest this is deleted.

My reasons for objection to the NHDC Local Plan are:
Lack of transparency in the process
Unapproved enlargement of site BK3 to include Herts County Council owned land
Lack of detail or explanation on numbers of housing requirements
Proposal of S106 contributions from developments being shared unfairly with Barley

I object to the Further Main Modifications to the North Hertfordshire Local Plan 2011 - 2031 (the Plan), May 2021.

My objection comes from the lack of transparency to several Further Modifications, including housing numbers for Barkway and contributions from development in Barkway towards sustainable travel to school. I also object to the justification for the integration of the Reserve School Site into BK3; and the lack of transparency in the process that has denied the Parish Council the opportunity to support the removal of BK3 from the Plan as requested by North Hertfordshire District Council (NHDC), or to object to a Further Modification not to remove BK3 from the Plan

I object to parts or the whole of the content of the following Further Modifications, including aspects of the justification put forward to support them.
MM010/FM039, p.32, Policy SP2, Settlement Hierarchy and Spatial Distribution
MM012/FM041, p.33, New paragraph after paragraph 4.12
MM217/FM113, p.144, Table after Policy BK3
MM215/FM111, p.144, Policy BK2
MM216/FM112, p.144, Policy BK3
MM219/FM114, p.144, Paragraph 13.39

I also object to the following Examination Documents which have been submitted to the Examination between November 2019 and March 2021:
ED170 Council's further response to Inspector’s Letter of 9 August (EX168)
ED 175 Council’s response to Inspector 9 July 2019

Finally, I object to the lack of transparency over this most recent part of the Examination process that has not provided the opportunity for the Parish Council to fairly state its case in relation to BK3, and the omission of a Further Modification refusing NHDC’s request to exclude BK3 from their Local Plan.

As a resident of Barkway I am very concerned about the recent Further modifications to the local plan, that does not include NHDC's request to exclude the BK3 development from the local plan.
There has been no public correspondence between the inspector and NHDC on the draft structure of FM's, only NHDC's assertion that the inspector has agreed the schedule of FM's.
The reasons for the inspectors decision not to accept NHDC's request to exclude BK3 from the local plan has not been published, also we have not had a fair or proportionate opportunity to put our case against the inclusion of site BK3. We support NHDC's request to remove site BK3 from their local plan.
Also examination document ED175. This document says that including the school site in the housing allocation site BK3 is pragmatic. HCC have not requested this amendment. This decision may be practical for NHDC but ifBK3 includes the HCCs land , then there is a risk that more homes than the allocation of 140 will be built on this site. The land is not required by HCC for a school and therefore should not be a part of housing site BK3.
MM010/FM039 Says the number of expected homes to be delivered in Barkway village in the local plan period is 208. There is no evidence given for this figure. This figure is critical because Barkway is identified as suitable to support higher levels of housing than VAT A village's on the basis that the number of homes expected to be delivered is 'more than 200', these figures need to be justified.
The contribution from the construction of new homes is mentioned three times in the Schedule Of Further Proposed Main Modifications. School transport is already provided, and BPC have been consulted on how S106 monies should be spent for the benefit of the Parish, if this modification was to remain in the Local Plan for a bus service between Barley and Barkway schools, Barley would be benefitting from the development in Barkway.
So with regard to Mm216/ FM111 " Contribution towards travel by sustainable modes of transport between Barley and Barkway schools"
We suggest that this is deleted.

To my surprise I have received correspondence in respect of a planning application/proposal for a development in Barkway which is back on the agenda. I understood this was to be removed from the local plan as Barkway was no longer seen as a 'village for growth' as suggested by an NHDC Planning Officer in 2020.

I would like to register my objection to this proposed development.

Reason for objection:

1. Transparency of the Process
• There has been no public correspondence between the Inspector and NHDC on the Draft Schedule of Further Modifications, only NHDC’s assertion that the Inspector has agreed the Schedule of Further Modifications.
• The reasons for the Inspector’s decision not to accept NHDC’s request to exclude BK3 from the Local Plan has not been published.
• We have not had a fair or proportionate opportunity to put our case against the inclusion of Site BK3. We support NHDC’s request to remove site BK3 from their Local Plan

2. Enlarging BK3 to Include Hertfordshire Country Council’s (HCC) School Site
Examination Document ED175. This document says that including the school site in the housing allocation site BK3 is pragmatic. HCC have not requested this amendment. This decision may be practical for NHDC but if BK3 includes HCCs land, then there is a risk that more homes than the 140 allocated will be built on this site. The land is not required by HCC for a school. The HCC school site should not be part of housing site BK3.

3. Figures for Housing Allocations, Completions and Permissions
MM010/FM039 says the number of homes expected to be delivered in Barkway village in the Local Plan period is 208. There is no evidence given for this figure. The figure is critical because Barkway is identified as suitable to support higher levels of housing that Category A villages on the basis that the number of homes expected to be delivered is ‘more than 200’. The figures need to be justified. MM217/FM113 is a table showing new homes for the parish. The table is wrong. Red type shows the figures given in the modification. Blue shows a simple correction. However, the detail of how the figures were arrived at is not available so the figures need to be justified. Total allocated sites 173 160 homes Completions and permissions 31 57 homes Total allocated, completed and permitted 204 230 217 homes

4. S106 Contributions to Provide School Transport
The contribution from construction of new homes in Barkway is mentioned three times in the Schedule of Further Proposed Main Modifications. School transport is already provided, and BPC have been consulted on how S106 money should be spent for the benefit of the parish. If this modification was to remain in the Local Plan for a bus service between Barkway and Barley schools, Barley would be benefiting from development in Barkway.
MM215/FM111 (in relation to Policy BK2): “Contribution towards travel by sustainable modes of transport between Barley and Barkway schools”. We suggest this is deleted.
MM216/FM112 (in relation to Policy BK3): “Contribution towards travel by sustainable modes of transport between Barley and Barkway schools.” We suggest this is deleted.
MM219/FM114 (in relation to Paragraph 13.39): “Contributions to support sustainable travel between the two sites should be secured from new developments.” There are no developments proposed in Barley, only in Barkway and we suggest this is deleted.

To my surprise I have received correspondence in respect of a planning application/proposal for a development in Barkway which is back on the agenda. I understood this was to be removed from the local plan as Barkway was no longer seen as a 'village for growth' as suggested by an NHDC Planning Officer in 2020.

I would like to register my objection to this proposed development.

Reason for objection:

1. Transparency of the Process
• There has been no public correspondence between the Inspector and NHDC on the Draft Schedule of Further Modifications, only NHDC’s assertion that the Inspector has agreed the Schedule of Further Modifications.
• The reasons for the Inspector’s decision not to accept NHDC’s request to exclude BK3 from the Local Plan has not been published.
• We have not had a fair or proportionate opportunity to put our case against the inclusion of Site BK3. We support NHDC’s request to remove site BK3 from their Local Plan

2. Enlarging BK3 to Include Hertfordshire Country Council’s (HCC) School Site
Examination Document ED175. This document says that including the school site in the housing allocation site BK3 is pragmatic. HCC have not requested this amendment. This decision may be practical for NHDC but if BK3 includes HCCs land, then there is a risk that more homes than the 140 allocated will be built on this site. The land is not required by HCC for a school. The HCC school site should not be part of housing site BK3.

3. Figures for Housing Allocations, Completions and Permissions
MM010/FM039 says the number of homes expected to be delivered in Barkway village in the Local Plan period is 208. There is no evidence given for this figure. The figure is critical because Barkway is identified as suitable to support higher levels of housing that Category A villages on the basis that the number of homes expected to be delivered is ‘more than 200’. The figures need to be justified. MM217/FM113 is a table showing new homes for the parish. The table is wrong. Red type shows the figures given in the modification. Blue shows a simple correction. However, the detail of how the figures were arrived at is not available so the figures need to be justified. Total allocated sites 173 160 homes Completions and permissions 31 57 homes Total allocated, completed and permitted 204 230 217 homes

4. S106 Contributions to Provide School Transport
The contribution from construction of new homes in Barkway is mentioned three times in the Schedule of Further Proposed Main Modifications. School transport is already provided, and BPC have been consulted on how S106 money should be spent for the benefit of the parish. If this modification was to remain in the Local Plan for a bus service between Barkway and Barley schools, Barley would be benefiting from development in Barkway.
MM215/FM111 (in relation to Policy BK2): “Contribution towards travel by sustainable modes of transport between Barley and Barkway schools”. We suggest this is deleted.
MM216/FM112 (in relation to Policy BK3): “Contribution towards travel by sustainable modes of transport between Barley and Barkway schools.” We suggest this is deleted.
MM219/FM114 (in relation to Paragraph 13.39): “Contributions to support sustainable travel between the two sites should be secured from new developments.” There are no developments proposed in Barley, only in Barkway and we suggest this is deleted.

See Attached

See Attached