MM 012 / FM 041

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.

See Attached Petition

See Attached

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.

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

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