MM 213 / FM 108

NHDC made it very clear in their Hearing Statement of February 2021 (Matter 30) that Site BK3 should be deleted, and that there is no reasonable likelihood of the reserve school site being required during the plan period.

NHDC have also made their concerns very clear regarding integration of BK3 in urban design terms. Without the school site, the new housing will be divorced from the built form of the village. In response to Question 30.1(c), NHDC clearly stated that the allocation should be deleted as it is no longer justified or consistent with national policy.
The revised wording for policy BK3 includes a “contribution towards travel by sustainable modes of transport between Barley and Barkway schools” in attempt to justify the sustainability of 140 new homes. However, this relies on young children using a bus to access First School provision and brings into question the settlement hierarchy of the whole Plan. If it is considered sustainable to rely on a bus service for a 140 dwelling development, then this opens up a number of other opportunities for similar scale developments in villages that lack full First School provision. This is not justified within the settlement hierarchy and makes the Plan unsound.
Quite correctly, in response to Question 30.3, NHDC made it clear that Barkway should be a Category A village. Para 13.35 of the Submission Local Plan inc. Further Modifications accepts that ‘facilities are limited’ in the village. This paragraph also attempts to justify the scale of new development as a response to Barkway’s ‘development needs’. However, a site for 140 new dwellings is not what the village needs, and is wholly disproportionate to the scale and character of the village, which has evolved as a linear settlement.

The table submitted by NHDC in response to Question 30.4(c) clearly highlights the disproportionate allocation of new housing for Barkway compared to 2011 population figures and current school provision for other settlements. This is not sustainable.

It is unclear why the Inspector would retain Site BK3 within the Plan on the basis of the evidence submitted, and NHDC’s own request for deletion. No correspondence has been made public to justify this position.

Ultimately, removal of site BK3 from the Plan will not undermine the Local Plan’s spatial strategy, will not compromise the Council’s 5 year supply position, nor will it have any wider implications. There is therefore no reason for this site to remain in the Plan. Site BK3 should be deleted and Barkway reinstated as a Category A Village. Retention of site BK3 within the Plan renders it unsound as it has not been positively prepared, and is not justified. The Local Plan is therefore in conflict with Paragraph 35 of the NPPF.

I am writing to submit my objections the Further Modifications to the North Hertfordshire Local Plan 2011-2031. I object to the following Further Modifications:

MM213/FM108 - I note the amendment stating that Barkway has been allocated "a greater amount of development". I understand this is a reference to the allocation of Barkway as a "Village for Growth". There is growing concern amongst the local community about the opacity surrounding the decision of the Inspectorate to ignore the submission in late 2020 by NHDC that Barkway should no longer be considered a "village for growth" and that BK3 should be removed from the Local Plan. 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 have not been published. As a result the local community have not been given fair opportunity to contribute to nor respond to this decision and have no way of holding decision makers accountable for the decision-making process nor to assess the validity of the factors leading to that decision. This is an outrageous breach of the principles of openness and fairness which are supposed to govern this procedure. This further modification should therefore be removed and BK3 should be taken out of the Local Plan in line with the request from NHDC.

MM219/FM114 - The further modification suggests that the existing school could accommodate the significant increase in pupils likely to result from the development of BK3 and further the allocated school site currently held in reserve by Hertfordshire County Council has now been added to the BK3 site for development. As a parent at to a student at the Barkway site, I can attest that the existing site could not accommodate significant additional students without compromising on the quality and comfort of the pupils. the Barkway site also houses Barkway Preschool whose children may not have been counted within the estimates. Barkway Preschool is a hugely valued asset to the local community, providing low-cost childcare for children between 2 and 4 years old. The preschool is only sustainable due to the low rent space provided to it by the school. An expansion of school pupil numbers into the current pre-school space would push the pre-school out of existence. It is hard to understand why the BK3 site would now include the HCC reserved school site unless the intention is to use this space not for educational purposes, as was intended, but to build more houses than was originally intended for the BK3 site. Finally, the amendment also suggests contributions toward the travel between the Barley and Barkway federated school sites would be a benefit drawn from the development of the BK3 site. In fact, travel between the sites is already provided for by a school bus.

MM217/FM113 - This modification is a table showing new homes for the parish. The table is extremely confusing. At the top, the suggestion is that 140 homes are planned for while the new table suggests 173 homes would be developed for the site. This disparity needs to be corrected or clarified and the figures need to be fully justified.

I am writing to submit my objections the Further Modifications to the North Hertfordshire Local Plan 2011-2031. I object to the following Further Modifications:

MM213/FM108 - I note the amendment stating that Barkway has been allocated "a greater amount of development". I understand this is a reference to the allocation of Barkway as a "Village for Growth". There is growing concern amongst the local community about the opacity surrounding the decision of the Inspectorate to ignore the submission in late 2020 by NHDC that Barkway should no longer be considered a "village for growth" and that BK3 should be removed from the Local Plan. 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 have not been published. As a result the local community have not been given fair opportunity to contribute to nor respond to this.

MM219/FM114 - The further modification suggests that the existing school could accommodate the significant increase in pupils likely to result from the development of BK3 and further the allocated school site currently held in reserve by Hertfordshire County Council has now been added to the BK3 site for development. As a parent at to a student at the Barkway site, I can attest that the existing site could not accommodate significant additional students without compromising on the quality and comfort of the pupils. the Barkway site also houses Barkway Preschool whose children may not have been counted within the estimates. Barkway Preschool is a hugely valued asset to the local community, providing low-cost childcare for children between 2 and 4 years old. The preschool is only sustainable due to the low rent space provided to it by the school. An expansion of school pupil numbers into the current pre-school space would push the pre-school out of existence. It is hard to understand why the BK3 site would now include the HCC reserved school site unless the intention is to use this space not for educational purposes, as was intended, but to build more houses than was originally intended for the BK3 site. Finally, the amendment also suggests contributions toward the travel between the Barley and Barkway federated school sites would be a benefit drawn from the development of the BK3 site. In fact, travel between the sites is already provided for by a school bus.

MM217/FM113 - This modification is a table showing new homes for the parish. The table is extremely confusing. At the top, the suggestion is that 140 homes are planned for while the new table suggests 173 homes would be developed for the site. This disparity needs to be corrected or clarified and the figures need to be fully justified.

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.

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

MM010/FM039 Page 32

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

MM213/FM108 Page 143

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

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

MM216/FM112 Page 144

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

MM219/FM114 Page 144

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

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

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

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

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

New Issues.

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

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

The Office for National Statistics.

The ONS has reduced housing numbers in North Hertfordshire.

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

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

This buffer is far too high.

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

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

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

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

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

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

Green Belt.

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

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

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

Pity that the public are ignored.

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.