MM 010 / FM 039

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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.

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.

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The position of the many people supporting the Save Our Green Belt group remains unchanged, despite the further modifications implemented and consulted upon now.

1. It is clear from these modifications that the population increase envisaged has not evolved and that the provision of New Homes will result in a significant oversupply.
2. As a consequence of incorrect MHCLG housing targets as confirmed by the Office for National Statistics (ONS), the target number of homes is at least 4 times and possibly 5 times the number actually required.
3. The decision to leave the additional 5,500 homes to the west of Stevenage safeguarded and not bring them forward in the first instance despite their close proximity to a major Town and consequent established urbanisation, has placed unnecessary pressure on many Villages, relied upon to infill in completely unsustainable locations, to support an irrelevant five year housing supply plan, which is totally unjustified.
4. In the age of the Covid pandemic, poor air quality and the growing need for climate change, there remains little justification in removing land from the protected Green Belt to build homes to support 90% of your intended development options.
5. As a consequence of the changing mood in government, society and the forgoing facts, the development of the “Villages for Growth” and those areas east of Luton are entirely incorrect and unjustified and therefore should be completely removed.
6. There are many other facts and objections raised previously by our group that remain unresolved by your modifications despite bringing those to the attention of the NHDC and the Planning Inspector previously.
We await the decision of the Inspector where it is hoped that common sense will prevail, failing which a statutory review will be requested.

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I am growing increasingly concerned of what I am hearing about the Schedule for Further Main modifications issued in February relating to BK3 land in Barkway.

There has been no attempt to justify how the total allocations for new housing in the village (MM010/FM039) has been justified. it seems to be an arbitrary figure, and considering the detrimental effect this housing development will have on the village, this seems to be of great concern.

Furthermore, the question then arises why has correspondence about the Draft Schedule of Further Modification between the Inspector and NHDC not been circulated to the residents of the village, as this decision affects us the most? Why did the Inspector not accept your request to exclude BK3 from the Local Plan and why has our Parish Council not been given a fair and proportionate opportunity to argue the strong case against including BK3?

This email is a written objection statement to the Further Modification to the North Hertfordshire Local Plan 2011 - 2031 (the Plan), May 2021.

As a resident of Barkway village, I am extremely concerned by the clear lack of transparency of the process relating to the schedule of Further Modifications. This lack of transparency has meant that we (residents) have not had a fair or proportionate opportunity to put our case against the inclusion of site BK3 to the plan.

I very much support NHDC's previous request to remove site BK3 from their Local Plan. It is shocking therefore to see the draft schedule for Further Modifications. There has been no public correspondence between the Inspector and NHDC on the draft schedule for Further Modifications, only NHDC's assertion that the Inspector has agreed the schedule for Further Modifications!

To add to this, there has also been no public correspondence explaining the reasons as to why the Inspectors decision not to accept NHDCs request to exclude BK3 from the Local Plan.

I also object to the proposed enlarged of BK3 to include Hertfordshire County Council's School Site. BK3 land is not required nor has been requested by Hertfordshire County Council. Therefore the inclusion of the School Site within the Examination Document ED175 in unjustified and should be removed.

It is stated numerous times in the Schedule of Further Modifications that the development of new homes in Barkway will provide contribution to school transport. School transport already exists. If this modification to introduce a bus service between Barley and Barkway was to remain, Barley would clearly be benefiting from the (over)development in Barkway.

Due to this I recommend that the following statements are deleted from the following documents, along with any reference to sharing contributions from development in Barkway with Barley:

MM215/FM111 "Contribution towards travel by sustainable modes of transport between Barley and Barkway schools”

MM216/FM112 "Contribution towards travel by sustainable modes of transport between Barley and Barkway schools”

MM219/FM114 "Contributions to support sustainable travel between the two sites should be secured from new developments.”

Finally the figures stated for Housing Allocations, Completions and Permissions are unjustified. MM217/FM113 states figures which have been given in the modification along with subsequent correction for these figures. However, no justification is provided for how the figures have been derived.
Please also note that MM010/FM039 states the homes expected to be delivered in Barkway village through the local plan period is 208. No evidence is given for this figure, nor has any justification been provided as to why Barkway has been identified as suitable to support housing levels higher than other Category A villages.

On a personal note, I am extremely concerned about the proposed development of new homes on the BK3 site. As a family we recently moved to Barkway from Royston for a quieter and more intimate village life within a beautiful and historic setting. We identified Barkway as a village where we felt it safe for our young children to grow up, knowing the quiet and safe nature of the local environment. A development such as the proposed BK3 would, without doubt, majorly impact this. The noise, traffic and pollution that a development like BK3 would be truly devastating for a village like Barkway, and an impact on a historic village which would be completely irreversible.

A development of 140 new homes in a small village which does not even possess a local shop seems completely irrational. The amount of increased traffic generated as new residents move in and out of the area would choke the village and key routes both in and out of Royston and Buntingford. Towns already under intense development themselves.

I sincerely hope that the technical challenges to the Local Plan listed above are appropriately responded to. I also hope that the personal plea to protect and preserve Barkway and the local area is positively considered.

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After much time and expense I thought that BK3 had been fully discussed and resolved: the Planning Officer at NHDC wrote to the Inspector requesting BK3 to be taken out of the Plan. Now I hear that it most certainly has not. BK3 is back on the agenda. Why?

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 Herts CC School site
• Examination Document ED17.This document says that including the school site in the housing allocation site BK3 is pragmatic. HCC has NOT requested this amendment. This decision may be practical for NHDC but if BK3 includes HCC's land, then there is a risk that more homes that the 140 allocated will be built on this site. The land is not required by HCC for a school and so it 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 time span 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 than 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 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:
o Total allocated sites: 173 corrected to 160 homes
o completions and permissions: 31 changed to 57 homes
o Total allocated/completed/permitted: 204 changed to 230 changed to 217 homes
4. S106 Contributions to Provide School Transport
• The contribution from construction to new homes in Barkway is mentioned 3 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". Suggest this is deleted.
• MM216/FM112 (in relation to Policy BK3: "Contribution towards travel by sustainable modes of transport between Barley and Barkway schools". Suggest this is deleted.
• MM219/FM114 (in relation to Paragraph 13.39): "Contribution to support sustainable travel between the two sites should be secured from new developments." There are NO developments proposed in Barley, only in Barkway. Suggest this is deleted.
It is very worrying that lack of TRANSPARENCY and lack of JUSTIFICATION are very much at the heart of BK3. It does not engender trust in North Herts and Hertfordshire County Councils' planning procedures.
I hope you will investigate this thoroughly and TRANSPARENTLY and ensure that we are dealt with fairly.
In addition to the above there are very real problems relating to an inadequate infrastructure (sewage etc) and inadequate country roads which would not be able to cope safely with the number of houses proposed.
Thank you for giving this your full attention.

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