1 INTRODUCTION

Thank you for consulting Welwyn Hatfield Borough Council on the Barkway and Nuthampstead Neighbourhood Plan.

The Council does not wish to make any representations.

I wish all parties well as the plan progresses to examination.

National Highways is a strategic highway company under the provisions of the Infrastructure Act 2015 and is the highway authority, traffic authority and street authority for the Strategic Road Network (SRN).

It has been noted that once adopted, the Neighbourhood Plan will become a material consideration in the determination of planning applications. Where relevant, National Highways will be a statutory consultee on future planning applications within the area and will assess the impact on the SRN of a planning application accordingly.

Notwithstanding the above comments, we have reviewed the document and note that the details set out within the draft document are unlikely to have an severe impact on the operation of the trunk road and we offer No Comment.

We have reviewed the content of the Neighbourhood Plan and confirm that Central Bedfordshire Council does not wish to make any representations.

We wish all parties well as the plan progresses to examination.

The County Council as landowner has no comments to make on the Submission Version of the Barkway and Nuthampstead Neighbourhood Plan.

Having read the Neighbourhood Plan for Barkway and Nuthampstead, please remove all mention of my property; Ashgrove. Photographs of the house have been included for which I did not give my permission, nor do I want them in a public document.

Mention is made of the ‘barn at Ashgrove’, it’s a stable not a barn. Please remove it from this document. The weather boarding that is mentioned is rotten and deteriorating, it requires replacement so mention of it is pointless if the building is to be preserved.

In the section of Leisure Facilities land at Burrs Lane is mentioned as Barkway Stud. There are two stable yards at the end of Burrs Lane, one belonging to the Smalley family and the other belongs to my family. Neither of them are a riding school, livery yard, petting zoo or animal sanctuary, ergo not a leisure facility for the village. They are for sole private use of the family that owns each of them. Kindly remove from the document.

I am aghast that Barkway Parish Council made sweeping statements about people’s property, did not seek any permission from owners for inclusion in the Neighbourhood Plan, and took hearsay in the village as gospel. I do not want my property mentioned or photographs of anything I own in this document.

Anglian Water supports neighbourhood plans and their role in delivering environmental and social prosperity in the region. Anglian Water has over 6 million customers as a water supply and water recycling provider. Our operational area spans between the Humber and Thames estuaries and includes around a fifth of the English coastline.

The region is the driest in the UK and the lowest lying, with a quarter of our area below sea level. This makes it particularly vulnerable to the impacts of climate change including heightened risks of both drought and flooding, including inundation by the sea. Additionally, parts of the area have the highest rate of housing growth in England.

Anglian Water has amended its Articles of Association to legally enshrine public interest within the constitutional make up of our business – this is our pledge to deliver wider benefits to society, above and beyond the provision of clean, fresh drinking water and effective treatment of used water. Our Purpose is to bring environmental and social prosperity to the region we serve through our commitment to Love Every Drop.

Anglian Water wants to proactively engage with the neighbourhood plan process to ensure the plan delivers benefits for residents and visitors to the area, and in doing so protect the environment and water resources. Anglian Water has produced a specific guidance note on the preparation of NPs found using this link under our Strategic Growth and Infrastructure webpage - Strategic Growth and Infrastructure (anglianwater.co.uk). The guidance also has sign posting/ links to obtaining information on relevant assets and infrastructure in map form, where relevant.

Anglian Water is the sewerage undertaken for the northern part of the neighbourhood plan area and is identified as a consultation body under the Neighbourhood Planning (General) Regulations 2012. Anglian Water covers the area in the northern part of Barkway village and includes Newsells and extending beyond to include other settlements such as Barley and Royston.

The following comments in relation to ensuring the making of the neighbourhood plan contributes to sustainable development and has regard to assets owned and managed by Anglian Water. Policy BN H5 Framework for BK3

Policy BN H3 Sustainable Construction and Policy BN H4 Design Codes

Water efficiency measures
Anglian Water is pleased to note that water efficiency is referenced within the neighbourhood plan. As a region identified as seriously water stressed, we encourage plans to include measures to improve water efficiency of new development through water efficient fixtures and fittings, including through rainwater/storm water harvesting and reuse, and greywater recycling. Whilst Anglian Water is only the statutory sewerage undertaker for the neighbourhood plan area, measures to improve water efficiency standards and include opportunities for water reuse and recycling (rainwater harvesting and greywater recycling) also reduces the volume of wastewater needed to be treated by our water recycling centres.
The Defra Integrated Plan for Water supports the need to improve water efficiency and the Government's Environment Improvement Plan sets ten actions in the Roadmap to Water Efficiency in new developments including consideration of a new standard for new homes in England of 100 litres per person per day (l/p/d) where there is a clear local need, such as in areas of serious water stress. Given the proposed national approach to water efficiency, Anglian Water encourages this approach. This will help to reduce customer bills (including for other energy bills) as well as reduce carbon emissions in the supply and recycling of water.
Flooding and Sustainable Drainage
Anglian Water is supportive of the measures to address surface water run-off, including the preference for this to be managed using Sustainable Drainage Systems (SuDS) and requiring permeable surfaces for new areas of hardstanding within developments to align with the drainage hierarchy. Such measures help to avoid surface water run-off from entering our foul drainage network, and connections to a surface water sewer should only be considered where all other options are demonstrated to be impracticable. Any requirements for a surface water connection to our surface water sewer network will require the developer to fund the cost of modelling and any upgrades required to accept the flows from the development.

Anglian Water encourages the use of nature-based solutions for SuDS wherever possible, including retrofitting SuDS to existing urban areas to enhance amenity and biodiversity within the neighbourhood plan area and contribute to green and blue infrastructure.

It is the Government's intention to implement Schedule Three of The Flood and Water Management Act 2010 to make SuDS mandatory in all new developments in England in 2024/ 2025. However, we welcome this policy to ensure SuDS measures are incorporated within new developments, until the Schedule is formally implemented and the necessary measures are in place.


Policy BN NE1 Local Green Space (LGS)

The policy designates areas LGS within the neighbourhood plan area. Anglian Water may have assets forming part of our water and water recycling network (e.g., rising mains and sewers) located near or adjacent to designated areas of local green space. It is noted that that the development is restricted to very special circumstances to be demonstrated. We consider that the policy provides scope for Anglian Water to undertake operational development to maintain and repair any underground network assets that may be within these areas, such as mains water pipes, and which would be consistent with this policy test.


Policy BN NE3 Conserve and Enhance Biodiversity

Anglian Water supports the policy objectives of prioritising the delivery of biodiversity net gains within the neighbourhood planning area to support habitat recovery and enhancements within existing areas green and blue infrastructure. Anglian Water has made a corporate commitment to deliver a biodiversity net gain of 10% against the measured losses of habitats on all AW-owned land.
As the neighbourhood plan progresses, there may also be benefit in referencing the emerging Local Nature Recovery Strategy (LNRS) by the Hertfordshire Nature Recovery Partnership, as this will identify priority actions for nature and map specific areas for improving habitats for nature recovery. Hertfordshire Nature Recovery Partnership | Hertfordshire County Council.

I have been able to get it confirmed that the assets I had previously referred to lying within the site allocation BK3 have been de-commissioned and the site is outside our statutory water boundary, so I have not needed to refer to this in my comments.

This representation is made by Hertfordshire County Council’s (HCC) Growth & Infrastructure Unit. Please see the below comments;

The Neighbourhood Plan contains the following two paragraphs. These are as follows;

1.9.5 Barley and Barkway VA Church of England First Schools Federation provides our children with a good primary education; however, the school is having to turn away children at nursery and reception ages because there are only 15 places per year for each of these age groups. Major redevelopment of the Barkway school buildings is required to provide 25 places for nursery and reception and to bring the teaching and learning environment up to modern standards.

4.6.1 There are currently surplus places at most age levels at local schools. The exception is for nursery and reception in the Barley and Barkway VA Church of England First Schools Federation for which only 15 places are available for each year’s intake, leading to children having to be turned away. A major redevelopment of the Barkway premises is required to increase capacity to at least 25 for nursery and reception and to update the teaching and learning environment of the school. Pressure on the places for these younger age groups would increase if BK3 were to proceed.


1.9.5 & 4.6.1: These paragraphs are not accurately written as is explained below. HCC would like to see these paragraphs re-written.

The Barley and Barkway Schools are in a Federation, the Published Admission Number (PAN) of Barley Church of England First School is 15 and the PAN of Barkway Church of England First School is 12, so in total the two schools currently offer 27 places. The nursery, Reception and Year 1 pupils are taught at the Barkway School site and Year 2, Year 3 and Year 4 pupils are taught at the Barley School site.

The summer 2024 school census data indicates the following numbers of pupils on roll:

School Name
Barkway (VA) C of E First
Year N - 18
Year R - 8
Year 1 - 10
Total = 36

Barley C of E (VA) First
Year 2 - 10
Year 3 - 13
Year 4 - 8
Total = 31

Both paragraphs 1.9.5 and 4.6.1 reference that a redevelopment of the premises is needed. There are already building works currently proposed at the Barkway School which have planning permission to make the current buildings more fit for purpose as the classrooms are small. The two schools are now combining PAN, there are technically the places for 27 1st preferences. These works are funded partly by the Diocese/school and partially S106 monies on the basis that if HCC needed them to expand their PAN by one or two places in the future they would. HCC has a signed funding agreement letter to this effect.

The Table above however demonstrates that the combined PANs are not at full capacity and HCC considers that there is sufficient capacity to mitigate demand from the new housing growth (including BK3 which has planning permission). The statement in both paragraphs that the school is turning away pupils in Reception is not true as there is no unmet demand currently in the village or the local area.

HCC therefore requests that using this information, both paragraphs 1.9.5 and 4.6.1 are entirely re-written to make it clear that there is sufficient capacity at the schools with more than 15 places available and that children are not being turned away.

HCC welcomes a discussion on these matters if useful, however no contact has been made to HCC by the school with any concerns over capacity.

See Attached

See Attached

Thank you for consulting us on the Barkway and Nuthampstead Neighbourhood Plan.

We have had to prioritise our limited resource and focus on strategic plans where the environmental risks and opportunities are highest. We attach our advice note which sets out our substantive response to Neighbourhood Plan consultations including Strategic Environmental Assessment screening and scoping.

We recognise that Neighbourhood Plans provide a unique opportunity to deliver enhancements to the natural environment at the local level. This advice note sets out the key environmental issues, within our remit, which should be considered. It also references sources of data you can use to check environmental features.

We hope this is helpful as you prepare evidence and the Neighbourhood Plan itself.

See attached Advice Note