MM 010 / FM 039

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I write to OJBECT to this wholly inappropriate unsustainable development of our small rural village.

By including site BK3 into the NHDC local plan I don't believe that the inspector has taken into account any of the following:

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.
• The villagers have not had a fair or proportionate opportunity to put our case against the inclusion of Site BK3 and support NHDC’s request to remove site BK3 from their Local Plan. mso-fareast-language:EN-GB">
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.

See attached.

To be clear, my objections are not based on the fact that I don't believe in changes or development, I understand that it is important to provide housing for an ever increasing population. My objection is in the fact that the sheer size of this development will completely change the character of Barkway and is a completely unsustainable proposal given the lack of infrastructure and amenities the village has.

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 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 fully support NHDC's previous request to remove site BK3 from their Local Plan. It is therefore extremely disappointing 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 outlining the reasons why the Inspectors did not 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 it been requested by Hertfordshire County Council. Therefore the inclusion of the School Site within the Examination Document ED175 in unjustified and should be removed. There are sufficient lower and primary schools within the area but little consideration appears to have been given to the increasing pressure this proposal will place on secondary/upper schools and the increased traffic in/out of Royston and Buntingford (to reach these schools), which are already heavily congested routes.

I would strongly dispute any traffic survey that has been carried out as part of the proposal, which does not recognise two key factors when reviewing the volume of traffic - 1) impact of Covid (heavily reduced traffic as many work from home and schools are closed or on staggered start/finish times) and 2) the impact of the other proposed housing development south side of Royston (for 300 new homes). Looking ahead 24-36 months, both proposals for additional housing will seriously and negatively impact in particular the two key routes in and out of Royston, the Barkway Road and A10. An additional lower/primary school in Barkway will not address this issue nor the need for children to receive a secondary education, which is currently via the nearest catchment school in Royston or alternatively, Buntingford. I drive along these roads daily, minimum 4 times to travel to work and to take children to school and even with the current reduced traffic (and without the additional housing) these routes can quickly become very congested due to the one way system in Royston.

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. For the reasons highlighted above, the proposed contribution to the school transport between Barkway and Barley will have absolutely no impact on the real issues created by 140 extra houses being placed in a small villages i.e. the two main roads in and out of the nearest town Royston, which can not support the additional traffic.

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.

I am extremely concerned about the proposed development for new homes on the BK3 site. We have recently made the decision to move to Barkway to improve our quality of life. Our primary focus was to improve our health and wellbeing and provide a safe environment for our children to grow up in with lower volumes of traffic and pollution. A development such as the proposed BK3 would, without doubt negatively impact this and have a destructive impact on the environment. 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 and one I can not comprehend. 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.

As a resident of Barkway, please see below my objections to the proposal and process.
1. Transparency of the Process - the most important issue
• 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 thefigures 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 homes. 160 homes is the corrected figure.
• Completions and permissions 31 homes. 57 homes is stated in the modification.
• Total allocated, completed and permitted 204 homes. 230 homes is stated in the modification, and 217 homes is the corrected figure.
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.

The proposed development is inappropriate and unsustainable for the village. In addition to environmental damage, bigger traffic problems, lack of local amenities and services, there is the question of demand for housing in the village in any case.

By including site BK3 into the NHDC local plan I don't believe that the inspector has taken into account any of the following:

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.
• The villagers have not had a fair or proportionate opportunity to put our case against the inclusion of Site BK3 and support NHDC’s request to remove site BK3 from their Local Plan. mso-fareast-language:EN-GB">
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.

To be clear, my objections are not based on the fact that I don't believe in changes or development, I understand that it is important to provide housing for an ever increasing population. My objection is in the fact that the sheer size of this development will completely change the character of Barkway and is a completely unsustainable proposal given the lack of infrastructure and amenities the village has.

I am writing to you to express my interest and dismay concerning future building development in Barkway.
This a long and evidently continuing saga as it remains unclear whether the specific site of BK3 is or is not to be included in the NHDC Local Plan for 2011-2031. It seems to me that this hinges on whether Barkway is considered a village for growth or not; which logically depends on the total of allocations, recent completions and existing permissions. This total number needs to be clarified and justified and settled once and for all, which does not seem to be the case at present. The continuing communications between NHDC Planning and the independent Inspector does not help to clarify the position. For instance, I note that in late 2020 a planning officer from NHDC requested that BK3 should be taken out of the Local Plan and that Barkway was no longer to be shown as a village for growth; yet when the latest Schedule for Further Main Modifications was announced in February 2021, BK3 was still included in the Plan. Furthermore, the reasons for this inclusion have not been published for general information and public consultation.
At the risk of reiterating previously stated points of view, it is my opinion that BK3 should not be included in the Local Plan for the following reasons:
1. The current building activities on the BK1 and BK2 sites would appear to me to be quite sufficient for the foreseeable future and commensurate with the current village infrastructure. Therefore, I have serious concerns about an additional 140 dwellings proposed for BK3.
2. Barkway has limited amenities, i.e. no shop, no surgery, no schooling provision beyond Year 4 and severely limited and ever diminishing public transport. The above application does not include any visible proposals to improve such infrastructure, apart from a proposed new shop. I suspect that there would be no guarantee that a future developer would build this shop nor is there any guarantee of its long-term sustainability as a stand-alone business. In any case a shop in Barkway would compromise the business of the existing and flourishing shop in Barley, our neighbouring village.
3. The development is at the extreme northern end of the village and north of an area reserved for provision of a new school. Thus, this development is effectively cut off from the rest of the village and is unlikely to encourage integration to sustain the vitality of the village and surrounding rural community.
4. The proposal will vastly increase the number and frequency of movements of private motor vehicles on the existing and narrow Royston and Cambridge Roads. I note that there is no intention to upgrade either of these approach roads. This increased movement will seriously increase the village carbon footprint and have a major impact on the local environment. This at a time when every effort should be aimed at reducing carbon footprint locally and globally.
5. It is already difficult to navigate Barkway High Street, Barley High Street and Hare Street at commute times, and more cars would definitely lead to traffic gridlocks.
6. Barkway stands on the extremity of the Chiltern Ridge. The proposed development will have a negative impact on the intrinsic character and beauty of the surrounding area and upon its wildlife. Together with the above comment, I believe this development to be environmentally unsound. Furthermore, when the natural flow of groundwater is disturbed, it could seriously compromise the water flow to the agricultural land to the north, towards Barley
7. Apart from the temporary employment afforded during construction, there is no evidence in this proposal of provision of any sustainable local employment or local business opportunities. Indeed, the concentration on residential property only does not apparently even provide for home business premises of any kind – an increased need since Covid.
8. The proposed site is currently a green field site and thus the development will take agricultural land out of any productive arable or grazing usage permanently. This is especially relevant now we are no longer in the EU. We should be conserving agricultural land, not taking it permanently out of food production.
9. The outline application proposes a mix of residential property the majority of which will command a high market value. The statement that up to 40% of the houses will be affordable is encouraging but there is no guarantee that any developer will adhere to this. This does little to inspire confidence for the younger generation in the village both now and in the future and will have a dramatic effect on the demographics and vitality of the village community.
There also appears to be a couple of other issues: namely a proposed extra inclusion of the HCC School Site into BK3 and a contribution to provide school transport between Barkway and Barley schools. The first issue would further increase the number of houses that could be built over and above the proposed 140 and transport between the two schools already exists. In any case if BK3 is not included in the Plan then these issues would become irrelevant and surplus to requirement.
I urge you to seek a reconsideration of the current situation and to oppose the inclusion of BK3 in the current Local Plan.

See Attached

The attached document identifies points in the text that in our view need to be clarified for soundness of the Local Plan. These points are offered as comments rather than by way of objection or approval. As required, the comments apply to the proposed changes shown in bold, red style and the immediate contexts that affect, and are affected by, the meanings of the proposed modifications.

The document is in Adobe Portable Document Format (PDF) and each comment is marked via two kinds of annotation:
• highlighting of the words referred to, unless that's an entire paragraph, and
• a 'speech bubble' to state our suggestion or query about the item.

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.

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I hereby raise the following objections to the proposed BK3 housing development in Barkway, North Herts:

1. The process has not been transparent
• 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. BK3 has been enlarged to include a site allocated for a school (Examination Document ED175), but HCC have not requested this amendment, and there is a risk that more than 140 homes will be allocated to be built on this site.

3. There is no evidence given for the 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, but 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’. MM217/FM113 is a table showing new homes for the parish, but the figures are incorrect and need to be justified.

4. This proposed development is not sustainable, particularly in terms of poor infrastructure and transport links; there is very little employment in the village.

I wish to lodge my strong objection to the inclusion of the above site in the North Herts Local Plan. This site is in the village of Barkway and has been included in the Local plan despite the local authorities, both North Herts District Council and Barkway Parish Council, requesting that the site be removed from the plan and that Barkway should no longer be viewed as a “ village for growth” .
I feel that the planning inspectorate has made an arbitrary decision without giving local people the opportunity to be included in the decision making process, nor have they explained the reason for this decision. In behaving in this way they are denying us the chance to have any say in the future of our village. Not only has this site been included but the inspector has taken it upon himself to enlarge the site by including land owned by Herts County Council which is allocated for a new school. There is no justification for including this additional area of land which would potentially allow a larger number of houses to be built. Barkway has no shop, no medical centre, very little employment and no secondary school. By substantially increasing the number of households in this area there will be serious impact on the environment, since the majority of those arriving in the village will have to travel by car to access shops, health care, school and employment. The schedule of further Proposed Main modifications mentions using s106 money for the provision of sustainable school transport between Barkway and Barley schools. Barley only has a primary school anyway and school transport is already provided. By using this money in this way Barley will benefit from development in Barkway and Barkway residents will have been denied the opportunity, Again, to influence a planning decision by having a say in how the money can be used for the benefit of the whole community. Secondary school age pupils would, in any case, have to travel to Buntingford or Royston for school so providing transport to Barley is illogical and unnecessary.
I have already pointed out the lack of amenities in Barkway. Local towns in the area are growing hugely; Buntingford, Standon and Bishops Stortford are set to almost double in size . These towns have all the amenities Barkway lacks and their residents are able to access them on foot, or by bike. Why build in an area without amenities when this will increase traffic on the roads and have a negative environmental impact?
Please hear the voices of those living in this area and take BK3 out of the local plan for good.

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As a resident of Barkway, please see below my objections to the proposal and process.
1. Transparency of the Process - the most important issue
• 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 homes. 160 homes is the corrected figure.
• Completions and permissions 31 homes. 57 homes is stated in the modification.
• Total allocated, completed and permitted 204 homes. 230 homes is stated in the modification, and 217 homes is the corrected figure.
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.
The proposal is inappropriate and unsustainable for the village. In addition to environmental damage, bigger traffic problems, lack of local amenities and services, there is the question of demand for housing in the village.

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As a resident of Barkway, please see below my objections to the proposal and process.
1. Transparency of the Process - the most important issue
• 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 homes. 160 homes is the corrected figure.
• Completions and permissions 31 homes. 57 homes is stated in the modification.
• Total allocated, completed and permitted 204 homes. 230 homes is stated in the modification, and 217 homes is the corrected figure.
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.
The proposal is inappropriate and unsustainable for the village. In addition to environmental damage, bigger traffic problems, lack of local amenities and services, there is the question of demand for housing in the village.

As a resident of Barkway, please see below my objections to the proposal and process.
1. Transparency of the Process - the most important issue
• 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 homes. 160 homes is the corrected figure.
• Completions and permissions 31 homes. 57homes is stated in the modification.
• Total allocated, completed and permitted 204 homes. 230 homes is stated in the modification, and 217 homes is the corrected figure.
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.
The proposal is inappropriate and unsustainable for the village. In addition to environmental damage, bigger traffic problems, lack of local amenities and services, there is the question of demand for housing in the village.

I am writing to object to certain Further Main Modifications to the North Hertfordshire Local Plan 2011 - 2031 (the "Modifications") (the "Plan").

I would urge all parties copied to this email to consider in very simple terms a situation where a local council has made two substantial recommendations in respect of its emerging local plan, which have been totally ignored by the relevant Inspector, without any reason provided publicly to justify that position.

Inclusion of BK3 in the Plan

I would like to express concern and disappointment that the Modifications have not removed site BK3 (a proposed development in Barkway) as recommended by North Hertfordshire District Council ("NHDC") in its Statement to the Further Hearings on Matter 30 - Barkway BK3 (the "NHDC Statement").

If the local council do not consider that this development should be included in the Plan then on what basis does it remain in the Plan?

There has been no public explanation provided as to the Inspector's decision not to accept NHDC's request. This has of course meant that there has been no fair or proportionate opportunity for any interested parties to comment on the continued inclusion of site BK3 against the explicit wishes of NHDC. This flies in the face of an open and transparent process, and tarnishes all the work stakeholders (including NHDC and the Inspector) have put in over a number of months to make consideration of the Plan a fair process available for scrutiny and challenge.

Objections to the Modifications proposed
MM010/FM039, p.32, Policy SP2, Settlement Hierarchy and Spatial Distribution
• Policy SP2 has been amended to state that there should be 208 houses delivered with the adjusted settlement boundary of the village of Barkway.
• This figure has not been justified, with no public explanation provided as to the calculation of this number. The "reason / source" provided in the Modifications does not elicit any further, useful information.
•This number cannot be included in the Plan without further justification.

MM012/FM041, p.33, New paragraph after paragraph 4.12
• This proposes a new paragraph providing that "Five villages have been identified that will support higher levels of new housing allocations than the Category A villages...[including] Barkway as a focus for development in the rural east of the District."
• The "reason" provided in the Modifications table is "for effectiveness".
• Barkway cannot support such higher levels of new housing allocations and has been wrongly identified.
•NHDC agrees with this position, as evidenced in the NHDC Statement, where it clearly explained that Barkway should be considered in a "separate tier of the hierarchy" to Knebworth, Codicote, Ickleford and Little Wymondley [the other four villages referenced in this new paragraph]" (see para 22).
• NHDC provided a number of compelling arguments in favour of Barkway not being classified with those other four villages. The Statement notes (at para 26) "Given its lesser sustainability credentials - by virtue of its smaller size, narrower range of facilities and operating under a three-tier...education system - the case for significant development in Barkway has always been far more marginal than in those Green Belt locations where equivalent levels of development are proposed."
• Furthermore, the Sustainability Appraisal Addendum Table 2 shows MM010/FM039 to include "Barkway is re-categorised as a Category A village". This has not been reflected in MM012/FM041 in the Modifications.
• There has been no evidence provided as to why NHDC's conclusions have been rejected (and why the Sustainability Appraisal Addendum Table has not been reflected) and therefore why Barkway remains in this category. This evidences the same issues of process and transparency as the continued inclusion of site BK3 above. On what basis is the Inspector making these decisions, directly in opposition to the position of NHDC?
• Barkway should be removed from the new paragraph proposed.
It is wholly improper that site BK3 be included in the Plan (as anticipated in the Modifications) and that MM012/FM041 includes Barkway as one of five villages to support higher levels of group given: (1) that is directly against the instruction of NHDC as evidenced in the NHDC Statement; and (2) without any public justification as to why NHDC's requests have been rejected.

To do so shames an entire process in which hard-working people (including those on the planning committees at NHDC and the Inspector) are otherwise doing their best to finalise a Plan which is appropriate for the constituents of this area.

See Attached