MM 216 / FM 112

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.

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.

I am writing to you with reference to BK3 planning application, and the North Hertfordshire Local Plan, to express my concerns about the transparency of the planning and planning review process.

Having received yet another letter from the parish council, following the latest update which shared the request from NHDC to the inspector to remove BK3 from the Local Plan, I now understand that BK3 is still in the plan.

There has been no public correspondence published on the discussion between the Inspector and NHDC on the Draft Schedule of Further Modifications, and no reason published on the Inspector's decision not to remove BK3 from the Local Plan. We have not had a fair or proportionate opportunity to put our collective case against the inclusion of BK3 in the local plan.

Further, there has been a fundamental failure from the beginning on behalf of the developer to engage with the community on the planning process. I am dismayed to have to write to yet again to share concerns in what feels like a drawn out, non transparent and undemocratic process.

Just to reiterate my specific concerns,

- No sustainable transport plan, significant concerns about the volume of traffic that will go down Barkway Road. Particular bottleneck in Royston. As a cyclist, particular concerns about the lack of viable options to either use public transport (no bike friendly bus service), or safely cycle to longer distance public transport option via the Barkway to Royston road. Entirely unclear how this aligns with the governments new plans to reduce carbon emissions in the short term. Aside from public transport concerns, there are not even plans to add in public charging points for electric vehicles.

- NHDC will normally permit development proposals if: The site lies within the main area of the village; and the proposal would maintain or enhance the character or visual quality of the village. NHDC were seeking to move the permitted development boundary of the village to include BK3 without prior consultation with the surrounding area. NHDC are now thankfully requesting BK3 be removed, but we now have the latest twist with this issue of lack of transparency between the NHDC and Inspector.

- Impact on the environment - the proposed site sits on the Chiltern Ridge, in a historic coaching village. New development would not form part of the village, impact on character

- Almost comical lack of local services in the village to support such an increased development. Pub that only serves beer, no shop, small school, inevitable Increased traffic to Barley and Royston (all via road) as a result.

Copying local elected representatives to flag my concerns about lack of transparency and poor governance on this critical planning process.

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 wish to object to further modifications to the Local Plan 2011-2031 on the grounds that 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.

Also, 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.

I trust you will take note of my views.

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.

I wish to object to further modifications to the Local Plan 2011-2031 on the grounds that 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.

Also, 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.

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I have objections to this planning application on the following points.

There has been no transparency leading up to this application because,
1. There has been no public correspondence between inspector and NHDC on the Draft Schedule of further modifications, only NHDC’s assertion that the inspector has agreed the Schedule for Further Modification
2. The reasons for the inspector’s decision not to accept NHDC’s request to exclude BK3 from the Local plan has not been published.
3. It is unfair that that we have not had the opportunity to put our case against the inclusion of Site BK3 and we support NHDC’s request to remove BK3 from the Local Plan.

As a nation we need to conserve our food production facilities and the removal any bit of greenfield or farmland is permanent and cumulative.
For a number of other reasons also, this site in Barkway is non sustainable.

This large number of houses should not be built on BK3 as there are very few businesses in the village to provide local employment. There would be a huge increase in the number of commuters to other work locations. This is against many planning rules.
Therefore the Government requirements for sustainability cannot be met as there would be insufficient local jobs available.

Already, commuters through Barkway, Hare Street and Barley have difficulty navigating the High Streets on the B1368 and an increase would not only cause more gridlock, but also a significant increase in pollution for people living in those locations. It is most unlikely that in the next decade or so that many people will be able to afford electric cars.

The poor connections of the local bus services will necessitate more car journeys to local amenities.

Barley and Barkway schools have a valuable amenity adjacent to BK3 where Newsells Stud has given the use of an area of woodland for their Forest School. Any building next to this would be highly unpleasant experience for the children.

Being on a high point of the Chilterns, this site is also a watershed for supporting the levels of moisture in the soil for local agriculture as BK3 is a high point in our local landscape. Destroying this natural movement of water might seriously compromise the supply of ground water to Newsells Stud and farms north of Barkway.

There is no call for another school site as the villages of Barley and Barkway support both schools very well and there is already well organised transport for the two sites.

The additional number of 140 houses proposed should surely be better located in or around towns where there would be public transport, jobs and amenities. In a rural village is not a good idea.

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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.

As long term residents of Barkway we are aware of the need for more housing in the area . This has already been met by a number of small developments. The suggested plans for BK3 are far too large for the village as there is not the infrastructure to support it.

What are the reasons for the decision of the inspector not to accept North Herts request to exclude BK3 from the Local Plan? Not knowing this has made it impossible for the village to put its case against this development.

We object to the development of BK3 and ask that the request by North Herts to exclude BK3 from the proposed developments of the local plan be adhered to.

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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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