MM 215 / FM 111

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I have been advised to comment specifically on the Further Modifications in order for my views to be considered. My concerns are as follows:

1/ The process has not been transparent and as such the development should not be allowed.

2/ The complete absence of public correspondence between the inspector and NHDC on the Draft Schedule of Further Modifications. We only have NHDC's assertion that the inspector has actually agreed the Schedule of Further Modifications.

3/ We have been given no reasons for the decision made by the Inspector not to accept NHDC's request to exclude BK3 from the Local Plan.

4/ Enlarging the Site to include the land owned by HCC is not in any way pragmatic. Just a means of adding extra houses to the development.

5/ The number of houses allocated compared to the table showing new homes for our parish are not the same. There is no justification for how these numbers were reached.

6/ The contributions to school transport/ sustainable transport suggested (MM215/FM11, MM216/FM112 and MM219/FM114) are also made without any thought for impact on the local villages or the roads. Plus Barley is not at risk from proposed developments so I can only conclude that this link will be to the new mega development that Royston residents are currently objecting to near Eagle Tavern on the Barkway Road. Buses would not be suitable for travel along the Newsells road and would be a major hazard. This all comes across as box ticking rather than actually considering impact on local communities.

We have not had anything approximating a fair or proportionate opportunity to put our case against the inclusion/development of Site BK3.

I fully support NHDC's request to remove BK3 from their local plan. Barkway should not be designated an area for such development.

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.

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I wish to raise the following objections to Further Modifications in relation to site BK3.

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, the specific ‘development need’ that the construction of 140 new dwellings would meet is not provided. Development of this magnitude and layout 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. Numerous pieces of correspondence have been published relating to the deletion of site BK3 including an apparently unchallenged statement from NHDC establishing the correctitude of the process of its deletion. The resulting absence of transparency casts great doubt on the veracity of the examination. Viewed against the magnitude of the proposed development that would increase the size of the village by in excess of 40% based upon 2011 census figures, the continued absence of correspondence on this matter leads only to the conclusion of Judicial Review should the plan be found sound with BK3 is included.
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.