MM 219 / FM 114

What constitutes sustainable travel between the two sites?
School minibus + driver would cost £20k+ initial costs plus (conservatively) £6000 per annum. Will these funds go directly to the the school?

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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.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Please see below my objections regarding the above:

1. Transparency of the Process

• 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 and the figures need to be justified.

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.