MM 216 / FM 112

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.

As has been exhaustively expressed by our Parish Council and many other personal submissions, I consider that the plot BK3 is wholly unsuitable for the proposed development of some 140 properties for the following reasons:

Barkway is an ancient linear village sited along the B1368 at the end of the Chiltern ridge. In 2011 it comprised 329 dwellings. Since then 31 homes have been given planning permission or completed. They have been designed in sympathy with local styles. [Local Plan p.144] Barkway has few amenities, requiring vehicular travel to access any shops, medical, dental and middle/secondary school facilities. It has a minimal bus service and the Neighbourhood Plan responses indicated an average car ownership of two per household.

BK3 -140 houses is wholly disproportionate in size to the existing village and will lead to a major increase in traffic, primarily travelling north, either through Barley (a single track High Street due to car parking) or up a road with two adversely cambered blind corners on a steep hill. This breaches both national and local sustainability criteria. The local roads are already dangerous, so safety will be compromised
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Due to a lack of foot-path on the west, the Rand land (2/3 of BK3) will be separated from the rest of the village without clear access to it, which could lead to low integration of the residents within the rest of the community. In the past, NHDC has always excluded BK3 from proposed land allocation plans as it did not meet the minimum appropriate criteria or have sufficient amenities to promote sustainable development.

How building on BK3 breaches The National Planning Policy Framework (NPPF) and Planning Practice Guidance (PPG).

Local Plan paragraph 1.7
In relation to local plans, matters covered by the NPPF include (but are not limited to) requirements to:
Properly assess the need for new development (known as objectively assessed needs) and planning to meet these insofar as is consistent with the framework. Where appropriate, carry out these assessments with regard to market areas which may cross administrative boundaries and ensuring that development needs across these wider areas are also met;
It is not clear that an isolated village of 329 houses has a need for a further 204 homes. [LP p144]
Protect existing Green Belt and only alter it in exceptional circumstances;
This proposal is to be built on Grade II agricultural land outside the village boundary.
Identify what infrastructure will be required to support planned development;
No added infrastructure has been suggested. The roads are already dangerous and every adult will require a car. A sewage farm, additional fresh water supplies, drainage, electricity and fast broadband will also be required; as will some means of connecting the site to the original village for pedestrians.
Address issues such as climate change and ensure a positive approach to the conservation and enhancement of natural and historic environments;
The site is next to Newsells, a thoroughbred horse stud-farm with prime grazing land adjacent to the bridleway separating it from BK3. It is the village’s largest employer.
Where potential harm to relevant natural or historic assets may occur, consider this against the public benefits that may arise from any proposed development.

Local Plan paragraph 1:10 - Relationship to Neighbourhood Plans
Neighbourhood plans have been introduced by the Localism Act 2011 and enable local communities to shape development in their area. These are plans produced by a parish council or a neighbourhood forum.

Barkway and Nuthampstead Designated Area Neighbourhood Plan is in process. An 82 item questionnaire was sent to all residents and achieved a 51% response rate. The overwhelming verdict of the neighbourhood is that the villages could cope with some 20% increase in house numbers, which would translate into some 65 new builds in Barkway. Half of these have already been built or agreed to.

Local Plan paragraph 2.83
Any new development will need to be located in places which have good access to jobs, shops, services and public transport and also provide opportunities to travel by foot or on a bicycle. Provision of measures for water conservation, improved biodiversity, increasing energy efficiency of new development, and renewable energy can help to ensure that development is more sustainable.
NPPF paragraph 11 - Conserving and enhancing the natural environment
The planning system should contribute to and enhance the natural and local environment by: protecting and enhancing valued landscapes…recognising the wider benefits of ecosystem services…minimising impacts on biodiversity and providing net gains in biodiversity.
Local Plan paragraph 11.62 and NPPF 125
Emphasise the importance of natural networks of linked habitat corridors to allow the movement of species between suitable habitats and promote biodiversity. River corridors are particularly effective in this way.

BK3 fails to fulfil these criteria. There is no footway linking Barkway and Barley - the location of the nearest shop and doctors’ surgery 2.5 miles away. There are minimal local employment opportunities. The commercially run bus service to Royston is infrequent and fails to run at suitable times for catching trains to work in Cambridge or London. The car parking by Royston station is already overstretched.
There is a roost of Pipistrelle bats in the local trees, which could well be disturbed by construction and human occupation. A local herd of fallow deer regularly crosses the B1368 and run straight across BK3 parallel with and south of The Reed Joint, a single track road linking Royston Road to the A10.

Local Plan section 3. - Spatial Strategy and Spatial Vision
3.3 Our spatial strategy is one of promoting sustainable development by supporting the use of suitably located previously developed land and buildings and by focusing the majority of development on our towns…in order to make maximum use of existing facilities, social networks and infrastructure, and maximise opportunities to deliver new infrastructure.
3.6 Spatial vision - [the aspiration is that:] New development will have contributed to the creation of sustainable communities. These are safe, attractive and inclusive; well-integrated into settlements; respect local distinctiveness; raise the standards of sustainable design and architectural quality; make a positive contribution to the local area; and ensure the protection, restoration and enhancement of valuable natural and historic resources. Strategic sites will have been master-planned in accordance with the guiding principles set out within this Plan.

Barkway is one of the few villages within NHDC which has a large housing development planned for it. As indicated, it has few existing facilities and infrastructure and BK3’s location predicates against its inhabitants integrating with existing village social networks.
Strategic sites were seemingly “master-planned” by NHDC by inviting local landowners to offer sites, irrespective of their suitability, and we contend that BK3 remains unsuitable as it has been deemed by NHDC in the past.

Strategic Policies - Sustainable Development - NPPF paragraph 14
At the heart of the National Planning Policy Framework is a presumption in favour of sustainable development, which should be seen as a golden thread running through both plan-making and decision-taking.
For plan-making this means that local planning authorities should positively seek opportunities to meet the development needs of their area.
BK3 with 140 houses is a disproportionally large site compared with Barkway and with it the village would expand by a top-heavy 65%.
For decision-taking this means approving development proposals that accord with the development plan without delay, and where the development plan is absent, silent or relevant policies are out-of-date, granting permission unless any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole; or carbon footprint increase to access amenities.
We consider that the adverse impacts of developing BK3 would significantly and demonstrably outweigh any benefits. Every adult will need a car, as demonstrated by there already being on average two cars per Barkway household. This would increase the carbon footprint. BK3 fails on any measure of sustainability.

Local Plan Policy SP1: Sustainable development in North Hertfordshire
c. Grant planning permission for proposals that, individually or cumulatively:
i. Deliver an appropriate mix of homes, jobs and facilities that contribute towards the targets and aspirations in this Plan;
No new jobs would be created and, were Newsells Stud to close down, some 30 -35 local jobs would be lost. A small village shop in the development would be unlikely to be viable as the existing shop/Post Office in Barley is already barely profitable.
ii. Create high-quality developments that respect and improve their surroundings and provide opportunities for healthy lifestyle choices;
Cycling to Barley, 2.5 miles and Royston, 5 miles, involves negotiating dangerous roads with blind corners on adverse cambers. There are no footways and a very infrequent bus service. Consequently, private car journeys would be necessary- not a healthy lifestyle choice.
iii. Provide the necessary infrastructure required to support an increasing population;
No road widening has been offered. The middle and secondary schools in Royston are at capacity, as is the Doctors’ surgery.
iv. Protect key elements of North Hertfordshire's environment including important landscapes, heritage assets and green infrastructure (including the water environment);
The Chiltern ridge, which runs along the Reed Joint, provides unimpeded views towards Cambridge and Ely. (The sun may be seen glinting off Ely Cathedral’s roof on occasions.) The bridleway running east-west along the south side of BK3 offers these views, which would become obscured by a housing estate.
v. Secure any necessary mitigation measures that reduce the impact of development, including on climate change;
One car per person would be required.
LP D1 Sustainable design policy 9.8
Development proposals should consider how the scheme will integrate with the existing circulation patterns particularly pedestrian, cycle and public transport. Safe and secure pedestrian and cycle routes should be provided both within the site and linking into the wider network. The policy seeks to ensure that the design and location of new development makes it accessible to all potential users. There is a need to ensure that where appropriate, new development includes facilities or open space that is conveniently located and easy to gain access to by all potential users.
There is no pedestrian passage way from the west side of BK3 into the rest of the village. This part is owned by the Rand Brothers. This is a wholly independent plot from that on the east side, which is owned by a different landowner.
NPPF 17, 95 & 112. Core Planning Principles combined with
Local Plan Policy SP1 - d.
Be genuinely plan-led, empowering local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the future of the area. 

i.e. Draft neighbourhood plan opinions should be considered.
Always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings;
Barkway has few amenities and BK3 development is unlikely to add to them. Our Neighbourhood Plan has been deemed to have insufficient independent evidence. This is being addressed.
Proactively drive and support sustainable economic development to deliver the homes, business and industrial units, infrastructure and thriving local places that the country needs. 

No economic activity would be added and 30 -35 jobs at the stud might be at risk.
Take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it.
BK3 does none of these things and is Grade II agricultural land at the end of the Chiltern ridge. It would destroy the character of the historic ‘linear’ village.
Support the transition to a low carbon future in a changing climate.
Every adult would need a car. Including the houses to be built on BK 1&2 on average, this would lead to an extra 346 cars at the north end of the village with associated traffic movements on narrow, dangerous roads.
Contribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value.
See above.
Actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable; and 
take account of and support local strategies to improve health, social and cultural wellbeing for all, and deliver sufficient community and cultural facilities and services to meet local needs.
BK3 detracts from any measure of sustainability.
LPP SP1 -d. Support neighbourhood plans and other local planning initiatives where they are in general conformity with the strategic policies of this Local Plan.
Barkway’s Neighbourhood Plan, which is still in process, clearly demonstrated the desires of the local populace. Over 51 percent of households responded to a comprehensive questionnaire, along with consultations in Parish meetings and through focus groups. Residents support modest, sympathetic house building which would increase the size of the housing stock by some 20% over 2011 levels, i.e.an extra 65 or so homes, preferably built on infill sites. Hence, in principle, Barkway Parish Council supports the development of BK1 & 2.

NPPF paragraph 28
Planning policies should support economic growth in rural areas in order to create jobs and prosperity by taking a positive approach to sustainable new development.
No jobs will be created after the building phase. No new amenities are proposed.

BK3 will also breach NPPFs 30, 34,35,37 and 38 as defined below.
NPPF paragraph 30
Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion. In preparing Local Plans, local planning authorities should therefore support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport
NPPF paragraph 34
Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised.
NPPF paragraph 35
Plans should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. Therefore, developments should be located and designed where practical to
– accommodate the efficient delivery of goods and supplies; 

– give priority to pedestrian and cycle movements, and have access to high 
quality public transport facilities.
NPPF paragraph 37
Planning policies should aim for a balance of land uses within their area so that people can be encouraged to minimise journey lengths for employment, shopping, leisure, education and other activities. 

NPPF paragraph 38
For larger scale residential developments in particular, planning policies should promote a mix of uses in order to provide opportunities to undertake day-to-day activities including work on site. Where practical, particularly within large-scale developments, key facilities such as primary schools and local shops should be located within walking distance of most properties.
NPPF paragraph 55
To promote sustainable development in rural areas, housing should be located where it will enhance or maintain the vitality of rural communities.
LP paragraph 4.35
Beyond our main towns, there is a steady demand for rural employment land and premises. Owing to the size and extensive spread of rural settlements these types of development are best dealt with on a case-by-case basis rather than through allocations, although our general approach will be to direct concentrations of rural business to the Category A villages. There are quite sizeable employment sites in villages such as Ashwell, Codicote, Kimpton, Little Wymondley and Weston which provide rural jobs and should be retained.

Barkway has been, in the opinion of the Parish Council, wrongly classified as a ‘Category A’ village, as it has few amenities and cars are required to access any shops, doctors’ surgeries, middle and secondary schools.

NPPF paragraph 72
The Government attaches great importance to ensuring that a sufficient choice of school places is available to meet the needs of existing and new communities. Barkway Voluntary Aided Church of England First School has places up to year 4. Above that travel to schools in Royston is required. These schools are already over-subscribed due to expansion in Royston. - it also contradicts NPPF 37
NPPF paragraph 123
Planning policies and decisions should aim to: avoid noise from giving rise to significant adverse impact on health and quality of life as a result of new development; mitigate and reduce to a minimum other adverse impacts on health and quality of life arising from noise from new development, including through the use of conditions; recognise that development will often create some noise and existing businesses wanting to develop in continuance of their business should not have unreasonable restrictions put on them because of changes in nearby land uses since they were established; and identify and protect areas of tranquillity which have remained relatively undisturbed by noise and are prized for their recreational and amenity value for this reason.
BK3 would have a negative impact on existing residents’ and Newsells stud farm’s peace, due to an in increase in traffic movements. Users of bridleways and foot paths through and around site would have a reduced user experience.

This is a sop towards sustainability.
* 140 houses means 280+ cars as there are no other means of transport
* cars will be used by parents taking children to school - in Barley and Barkway. There is daily traffic chaos outside both schools at the moment.
* Walking to Barley is almost impossible because of a lack of footpaths. Of course, parents could invest in cross-county buggies.
* Has this been sustainable transport been costed? In perpetuity, or just until the next round of cuts, or until S106 money runs out?

See Attached Change.Org Petition

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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.

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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.

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I wish to express my strong objection to Barkway BK3 being included in the local plan especially after NHDC requested that it be excluded. My concerns / objections are as follows:

1. NHDC requested that BK3 be excluded but this request has not been accepted. The process has been far from transparent - and this seems to be a disagreement between professionals that will have a huge effect on a small village

All correspondence between the inspector and NHDC on the Draft Schedule of Further Modifications relating to BK3 must be published.

Please treat this as a request under the Freedom of Information Act 2000 for this information to be disclosed.

2. Those who object to the suitability of BK3 must be given a chance to put their case once the above has been published.

3. Examination document ED175. HCC have not requested that the school site be included in housing allocation site BK3. The land is not required for a school and should not be part of the housing site. As such BK3 is not a suitable site as it is not connected with the rest of the village.

4. There are several material mistakes in the published documentation - these alone require a review of the decision. For example the tables showing new homes for the parish in MM217/FM113 do not agree / are wrong and include double counting. Another example relates to the S106 contributions where it proposes spending the money for the benefit of Barley (MM219/FM114 paragraph 13.39, MM216/FM112 in relation to BK3, MM215/FM111 in relation to BK2). It is wrong to suggest taking S106 contributions from a village that has a huge new housing development and spending it for the benefit of another village which does not have any proposed developments.

Clearly if decisions have been made on incorrect facts and assumptions the decision needs to be reviewed. Once we have access to the correspondence between the inspector and NHDC there may be further errors uncovered requiring further review.

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.

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My reasons for objection to the NHDC Local Plan are:
Lack of transparency in the process
Unapproved enlargement of site BK3 to include Herts County Council owned land
Lack of detail or explanation on numbers of housing requirements
Proposal of S106 contributions from developments being shared unfairly with Barley

I object to the Further Main Modifications to the North Hertfordshire Local Plan 2011 - 2031 (the Plan), May 2021.

My objection comes from the lack of transparency to several Further Modifications, including housing numbers for Barkway and contributions from development in Barkway towards sustainable travel to school. I also object to the justification for the integration of the Reserve School Site into BK3; and the lack of transparency in the process that has denied the Parish Council the opportunity to support the removal of BK3 from the Plan as requested by North Hertfordshire District Council (NHDC), or to object to a Further Modification not to remove BK3 from the Plan

I object to parts or the whole of the content of the following Further Modifications, including aspects of the justification put forward to support them.
MM010/FM039, p.32, Policy SP2, Settlement Hierarchy and Spatial Distribution
MM012/FM041, p.33, New paragraph after paragraph 4.12
MM217/FM113, p.144, Table after Policy BK3
MM215/FM111, p.144, Policy BK2
MM216/FM112, p.144, Policy BK3
MM219/FM114, p.144, Paragraph 13.39

I also object to the following Examination Documents which have been submitted to the Examination between November 2019 and March 2021:
ED170 Council's further response to Inspector’s Letter of 9 August (EX168)
ED 175 Council’s response to Inspector 9 July 2019

Finally, I object to the lack of transparency over this most recent part of the Examination process that has not provided the opportunity for the Parish Council to fairly state its case in relation to BK3, and the omission of a Further Modification refusing NHDC’s request to exclude BK3 from their Local Plan.