MM 010 / FM 039

Schedule of Further Proposed Modifications to the North Hertfordshire Local Plan 2011-2031

MM010/FM039 Page 32

The phrase will be delivered is incorrect. The Inspector and NHDC do not have the power to guarantee delivery. Delivery is dependent upon economic circumstances, democracy and the desire of the landowner to develop.

MM213/FM108 Page 143

This paragraph seeks to justify a disproportionate amount of development in Barkway; reasoning that it has the largest in population terms of the three villages to the east of the A10 and south of Royston.

The population of Barkway is virtually the same as the population of Barley. In any event the size of the village is irrelevant. As Officers and the Inspector know, development is based upon other factors, sustainability, proximity to services, employment and availability of land. As the Inspector and Officers also know, Barkway has few services and yet Barley has more, yet Barley has not been categorised as a village for growth, whilst Barkway strangely has. Barley is also closer to the numerous missing services, which are located in Royston.

MM216/FM112 Page 144

The new suggestion of a contribution towards travel by sustainable modes of transport between Barley and Barkway schools it's not realistic. There is no other source of money available to provide this service; therefore it would have to use all the S106 contributions, leaving nothing for Barkway village in general. This benefit would then be shared 50-50 between Barkway and Barley, with Barkway only benefitting in part. The cost of providing this transport, effectively in-perpetuity, will far exceed any S106 money that is likely to be available (circa £500,000.00). The Parish Council has already been consulted and agreed how any S106 money could be allocated. This proposal contradicts that agreement.

MM219/FM114 Page 144

The NHDC Officer responsible for preparing the Plan, Recommended that site BK3 be removed from the ELP. He prepared a well argued report explaining why. The Inspector has decided that the Officer's report justifying the removal of BK3 is not relevant, thereby leaving BK3 within the ELP. The Inspector has not produced any report explaining why he reached his decision.

It should be remembered that the NHDC Plan Officer has lived with the evolution of this Plan over several years and has a better understanding of it than anybody else.

It cannot be acceptable to ignore the Officer's recommendation without providing a well argued reason why.

The ELP was submitted to the NHDC Cabinet 16th March 2021 and approved at that stage with BK3 included. The Cabinet were not able to understand any rationale as to why BK3 was included and not excluded. Therefore the Cabinet took their decision to approve with insufficient information. This decision and all the background arguments must render the Plan unsound and likely subject to Judicial Review.

It has also been explained to me by two NHDC Officers that the actual reason for not removing BK3, was that it would be too controversial. In that it would encourage other selected settlements to argue as to why their selected sites should not be removed.

New Issues.

Barkway has now been selected as a village for growth. The Officer and Inspector acknowledge that Barkway has limited services et cetera. Yet Barley, is acknowledged as having a far greater selection of services has not been categorised as a village for growth.

This, is not logical. The selection of Barkway as a village for growth, is clearly not based on the suitability of the village, only that there is a large piece of land potentially available. Discounting the negative consequences of this recommendation. Particularly the largest employer in the area, Newsells Park Stud.

The Office for National Statistics.

The ONS has reduced housing numbers in North Hertfordshire.

Originally housing numbers in North Herts were calculated at approximately 14,500 Plan ending 2031 (Excluding unmet needs but including a buffer of around 8% or approximately 1,160 houses).

However because of the current modifications by the ONS, these numbers are being reduced from 14,500 to around 11,500. A similar 8% buffer within this new figure of 11,500 would amount to 920 extra homes. In terms of selected sites, the ELP is much as it was, thus Increasing the buffer to approximately 37% or 3,920 homes).

This buffer is far too high.

This results in what now appears to be an unnecessary threat to some greenbelt, when there is little prospect of houses being built on much of this valuable greenbelt within the Plan period.

It would make more sense for the Inspector to include a reasonable buffer and remove land that is perhaps of marginal suitability in particular greenbelt.

The consequence of this strange way of doing things; is that some homeowners, who live close to selected sites including greenbelt are having their properties unnecessarily blighted and many suffering stress; whilst I appreciate that house prices are not a planning issue. This blight is completely unnecessary.

In addition, some tenant farmers that are renting land that is in green belt are also under the wrong impression that some of their land will be taken from them for housing. This has the effect of not only subjecting them also to unnecessarily stress but stopping them investing in their businesses because they think some or all of their land will be sold off shortly.

The obvious option, is for the selected sites to bear a realistic relationship to the ONS housing numbers.
The Inspector should include a sensible buffer of around 8% and take out specific sites that are less suitable for development.

I understand the reason for this weird way of doing things. Is that it is easier for the Inspector and for those involved to leave all the sites in.

Green Belt.

Government says time and again, that they will "continue to protect and enhance the greenbelt". Yet, it will permit NHDC to build on it.

Finally, it is disappointing that of the thousands of representations submitted by a concerned public and many organisations. Not one site has been removed from the ELP.

We have spent an enormous amount of time and emotional effort in trying to steer the Plan in a realistic direction all without success.

Pity that the public are ignored.

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.

Please note my objections to the inclusion of the bk3 site to the local plan (yet again) as follows.

-I object because it’s in an inappropriate development in an area that cannot support it.

-A development as large as this in a rural village will have a detrimental effect on the character of Barkway both in terms of how it will physically change the landscape, and the strain it will put on an already strained infrastructure not just in Barkway but Barley too with the increase in traffic in particular - something we already have a rather large problem with as it is in barley without any real solution in sight.

- if you’ve been through Barkway at school drop off time, you’ll note the high probability of possible accidents on the junction that leads to this very site. It’s a surprise it hasn’t happened already let alone with a further 300 odd car movements happening in the early morning around the same location, same time.

- I’m not even sure why a development of this size in a rural village is being considered given how badly it is supported in all the necessary infrastructure factors required.

I am writing to object to the above planning application on a number of grounds.

1. I understand that late last year, an NHDC Planning Officer wrote to the Inspector requesting that Barkway be no longer classified as a “Village for Growth”. This would presumably have had the effect of halting BK3 development at source. However, we now discover that BK3 is still included in the Schedule of Further Main Modifications, without any reason being given - nor an opportunity to make the case against the inclusion. Any final approval should be delayed until local bodies have been given the chance to make their case, if the process is to be seen as fair and transparent. I would most emphatically support NHDC’s request to remove site BK3 from the Local Plan.

2. Barkway is surely one of the least suitable sites in the county for such a hugely disproportionate addition to its housing stock. There are virtually no opportunities for employment, implying that residents will need to travel at least as far as Royston (and probably further) to find jobs. There is no doctor’s surgery, no shop, and extremely limited public transport.

3. If 140 houses are built, therefore, each household will need to possess at least one car (probably more, especially where young adults living in parental homes are concerned). I understand that planning applications for 25 homes at land next to Royston Road have already been turned down on the grounds that local roads are insufficient to handle the increased traffic. What, then, is the logic in allowing an even larger number of houses to be built? I would suggest that planning officials visit Barkway at peak periods - rush hours, the beginning and end of the school day, for example - and see for themselves the congestion that already exists on the High Street and on the road into Royston.

4. The application would appear to go against several widely-publicised governmental objectives - for example, the requirement that new developments should be “sustainable”. The lack of employment referred to above means that the damaging effects of the development will far outbalance the benefits of creating new homes. Affordable housing, for instance, is pointless if the costs of commuting make them impracticable for the people most in need of such accommodation, which should be built where amenities like public transport, schools, surgeries etc. are more conveniently available.

5. There are also substantial environmental considerations, and it would be good to know that these had been addressed. The additional emissions of (say) 200 extra cars to the environs of a small village will be considerable and will militate against a number of planning guidelines concerning pollution and sustainability.

Please consider my objections seriously.

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I strongly object to the Schedule of Further Main Modifications to the Local Plan for Barkway, insofar as it pertains to the development of BK3.

In late 2020 the Planning Officer at NHDC requested BK3 to be taken out of the Local Plan and Barkway was not to be shown as a “village for growth”.
There were strong and good reasons for this and the local community had been consulted (as requested by the Prime Minister).

When the Schedule of Main Modifications to the Local Plan were published, it was clear that the recommendations of the Planning Officer had been ignored.
No reasons have been given for this decision.

This is a fatal flaw in the process and my objection is that a due and transparent process has not been followed.

You must be aware that there are powerful reasons for removing Barkway's designation as a “village for growth”, so that, if they are to be overruled, a proper and transparent procedure must be followed.

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