Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

Objection to the inclusion of site BK3 in the Local Plan
I would like to comment on the Further Modifications to the NHDC Local Plan and register my objection to the re-introduction of the site BK3 into the North Hertfordshire Local Plan for the following reasons:
Transparency of the process
• I understand that in 2020 an NHDC planning officer requested that BK3 was removed from the draft plan and that Barkway was no longer identified as a ‘village for growth’. However, following this when the schedule of further main modifications was published BK3 remained in the plan. It is unclear as to why BK3 remained in draft document.
• 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.
• There has not been a fair or proportionate opportunity for the local community/Parish Council to put their case against the inclusion of Site BK3.
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.
• I understand that HCC have not requested this amendment and the land is not required by HCC for a school, therefore the HCC school site should not be included as part of BK3.
Figures for Housing Allocations, Completions, and Permissions
• MM010/FM039 states that the number of homes expected to be delivered in Barkway village in the Local Plan period is 208. I understand that there is no evidence given for this figure? The figure identified needs justification.
• MM217/FM113 sets out the number of new homes identified for the parish. There appears to be some errors in this table and the detail of how the figures were arrived as it not available. Justification of these figures should be provided.
For the above reasons I would like to register my objection to the retention of BK3 in the Local Plan. It is not justified for a number of reasons and renders the Plan unsound as it has not been positively prepared and therefore means that it is in conflict with Paragraph 35 of the NPPF.