Local Plan 2011-2031 Proposed Submission Draft

I wish to place an objection to the Local Plan proposed Submission paragraph 13.37, and request that site ref BK3 is removed from the plan. I am of the opinion that the Plan is not sound as this paragraph contravenes National Planning Policies under the National Planning Policy Framework (NPPF).
The NPPF clearly states the "presumption in favour of sustainable development".
I do not think that site BK3, together with sites BK1 and BK2 in the village of Barkway, is sustainable. It goes against several sections of the NPPF and is contrary to NHDC's own policies.
Barkway is a historic village of a linear character. It is situated at the end of the Chiltern ridge. Since 2011, when dwellings numbered 329, planning permission has been granted for an additional 31 homes, which have been carefully designed to be in character with the rest of the village. Barkway has very limited amenities, so necessitates nearly every adult to own a vehicle.
NHDC proposes allocating 3 sites at the northern end of Barkway. BK1 (13 dwellings), BK2 (20 dwellings) and BK3 (140 dwellings). I do appreciate that some development is necessary and that NHDC has to meet the target for providing more housing across the region and that in that respect small scale sites such as BK1 & 2, which are carefully located and designed, are appropriate for Barkway. The proposal for BK3 is a totally disproportionate size to the existing village and as Barkway has such few amenities it will lead to a massive increase in the carbon footprint of the community with necessary use of private vehicles. It should be noted that the nearest shop/doctor is 2.5 miles away and secondary schooling even further. The bus service is very limited and there is no safe, lit pathways or cycleways to connect Barkway to other villages or towns. It should also be mentioned that Barkway has very little employment opportunity within walking or cycling distance. These points emphasise the total unsustainability of a development such as BK3 within this village.
It must be mentioned that NHDC has not acknowledged the proximity of site BK3 to Newsells Park, which is the largest employer in the village. This thriving stud farm will be grossly negatively affected by the closeness of site BK3 to their prime grazing field. The owners are now concerned about the future of their business. This contravenes NPPF para 28 - Creation of employment and prosperity.
In all other previous drafts of the Proposed Submission Local Plan (PSLP) site BK3 has been excluded or rejected. Nothing has changed since the previous drafts in relation to site BK3, so the same reasons should still apply, making this proposed site unsuitable.
NPPF paragraph 14 - "Presumption in favour of sustainable development". The benefit of new homes on site BK3 must demonstrably outweigh their adverse effect....
The proposed development on site BK3 is right on the edge of the existing village development boundary and the design makes it separate from the rest of the village and it is very likely to become a satelite area and not integrate well with the community. The size of the development will overwhelm Barkway, having a negative effect on the village. There are no proposals to enhance infrastructure or local amenities. Although there is a mention of the provision of a shop, NHDC cannot guarantee that a developer would include this or that somebody would want to take on the financial risk of running a shop. Village shop businesses are notoriously likely to fail. This proposal also contradicts PSLP section 3.7, Strategic Objectives, ECON6, which says "Sustain the vitality of our villages and the rural economy in supporting rural diversification whilst ensuring development is of an appropriate scale and character".
This site is also shown to be unsustainable by:
NPPF para 112 - Agricultural land use. Site BK3 is grade II agricultural land. This fact was stated as a reason for previously rejecting this site. Lower graded sites have been rejected in villages with far more available amenities than Barkway.
NPPF para 125 - Impact of light pollution - NHDC's PSLP (para 4.150) says it needs to protect the East Anglian Heights which include the Chiltern Ridge. BK3 is now proposing a housing development with street lighting! This exposed site will be visible for many miles from the north.
NPPF paras 11 and 109 - Conserving and enhancing the natural environment - BK3 is a wildlife corridor for fallow deer and a roosting place for the endangered pipistrelle bats.
In the NHDC landscape character Assessment for Barkway it emphasised the need for the Barkway Plateau to be improved and conserved.
The BK3 development contravenes the following NPPF policies on Sustainable Transport: NPPF, para 30 (reducing emissions), 34 (maximising use of sustainable transport), 37 (minimise need for travel for work, shopping, leisure and education) and 95 (moving to a low carbon future). An additional homes could mean 280 more private vehicles in the village.
NHDC has not given any evidence that there will be any improvement of public (sustainable) transport or enhancement of the minor road network which connects the village to necessary amenities. This contravenes PSLP Strategic Objectives Econ 8 - "Ensure that all development is supported by the necessary provision of, or improvements to infrastructure, services and facilities in an effective and timely manner to make development sustainable and minimise its effect upon existing communities".
It should also be mentioned that, although Barkway does have a primary education facility for up to age 9, there would be no safe way of walking to school from site BK3 as there is no street lighting or continuous pavement.
A recent representation from Campaign for Rural England Hertfordshire concluded that it thought BK3 was not sound as it was not consistent with the NPPF and was not justified.
I believe that the inclusion of site BK3 in the PSLP would lead to an unacceptable growth of the village (62% increase between 2011 and 2031) and is contrary to the wishes and vision of residents for the future of the village (as demonstrated by the Barkway and Nuthampstead emerging Neighbourhood Plan). It contradicts numerous policies within the NPPF and would lead to a non-sustainable development which would irreversibly negatively alter the historic character of Barkway and adversely affect the environment, all far outweighing the benefit of the development. I would strongly urge that site BK3 is removed from the Plan.