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

I wish to raise the following objections to Further Modifications in relation to site BK3.

NHDC made it very clear in their Hearing Statement of February 2021 (Matter 30) that Site BK3 should be deleted, and that there is no reasonable likelihood of the reserve school site being required during the plan period.

NHDC have also made their concerns very clear regarding integration of BK3 in urban design terms. Without the school site, the new housing will be divorced from the built form of the village. In response to Question 30.1(c), NHDC clearly stated that the allocation should be deleted as it is no longer justified or consistent with national policy.
The revised wording for policy BK3 includes a “contribution towards travel by sustainable modes of transport between Barley and Barkway schools” in attempt to justify the sustainability of 140 new homes. However, this relies on young children using a bus to access First School provision and brings into question the settlement hierarchy of the whole Plan. If it is considered sustainable to rely on a bus service for a 140 dwelling development, then this opens up a number of other opportunities for similar scale developments in villages that lack full First School provision. This is not justified within the settlement hierarchy and makes the Plan unsound.
Quite correctly, in response to Question 30.3, NHDC made it clear that Barkway should be a Category A village. Para 13.35 of the Submission Local Plan inc. Further Modifications accepts that ‘facilities are limited’ in the village. This paragraph also attempts to justify the scale of new development as a response to Barkway’s ‘development needs’. However, the specific ‘development need’ that the construction of 140 new dwellings would meet is not provided. Development of this magnitude and layout is wholly disproportionate to the scale and character of the village, which has evolved as a linear settlement.

The table submitted by NHDC in response to Question 30.4(c) clearly highlights the disproportionate allocation of new housing for Barkway compared to 2011 population figures and current school provision for other settlements. This is not sustainable.

It is unclear why the Inspector would retain Site BK3 within the Plan on the basis of the evidence submitted, and NHDC’s own request for deletion. No correspondence has been made public to justify this position. Numerous pieces of correspondence have been published relating to the deletion of site BK3 including an apparently unchallenged statement from NHDC establishing the correctitude of the process of its deletion. The resulting absence of transparency casts great doubt on the veracity of the examination. Viewed against the magnitude of the proposed development that would increase the size of the village by in excess of 40% based upon 2011 census figures, the continued absence of correspondence on this matter leads only to the conclusion of Judicial Review should the plan be found sound with BK3 is included.
Ultimately, removal of site BK3 from the Plan will not undermine the Local Plan’s spatial strategy, will not compromise the Council’s 5 year supply position, nor will it have any wider implications. There is therefore no reason for this site to remain in the Plan.
Site BK3 should be deleted and Barkway reinstated as a Category A Village. Retention of site BK3 within the Plan renders it unsound as it has not been positively prepared, and is not justified. The Local Plan is therefore in conflict with Paragraph 35 of the NPPF.

I wish to raise the following objections to Further Modifications in relation to site BK3.

NHDC made it very clear in their Hearing Statement of February 2021 (Matter 30) that Site BK3 should be deleted, and that there is no reasonable likelihood of the reserve school site being required during the plan period.

NHDC have also made their concerns very clear regarding integration of BK3 in urban design terms. Without the school site, the new housing will be divorced from the built form of the village. In response to Question 30.1(c), NHDC clearly stated that the allocation should be deleted as it is no longer justified or consistent with national policy.
The revised wording for policy BK3 includes a “contribution towards travel by sustainable modes of transport between Barley and Barkway schools” in attempt to justify the sustainability of 140 new homes. However, this relies on young children using a bus to access First School provision and brings into question the settlement hierarchy of the whole Plan. If it is considered sustainable to rely on a bus service for a 140 dwelling development, then this opens up a number of other opportunities for similar scale developments in villages that lack full First School provision. This is not justified within the settlement hierarchy and makes the Plan unsound.
Quite correctly, in response to Question 30.3, NHDC made it clear that Barkway should be a Category A village. Para 13.35 of the Submission Local Plan inc. Further Modifications accepts that ‘facilities are limited’ in the village. This paragraph also attempts to justify the scale of new development as a response to Barkway’s ‘development needs’. However, the specific ‘development need’ that the construction of 140 new dwellings would meet is not provided. Development of this magnitude and layout is wholly disproportionate to the scale and character of the village, which has evolved as a linear settlement.

The table submitted by NHDC in response to Question 30.4(c) clearly highlights the disproportionate allocation of new housing for Barkway compared to 2011 population figures and current school provision for other settlements. This is not sustainable.

It is unclear why the Inspector would retain Site BK3 within the Plan on the basis of the evidence submitted, and NHDC’s own request for deletion. No correspondence has been made public to justify this position. Numerous pieces of correspondence have been published relating to the deletion of site BK3 including an apparently unchallenged statement from NHDC establishing the correctitude of the process of its deletion. The resulting absence of transparency casts great doubt on the veracity of the examination. Viewed against the magnitude of the proposed development that would increase the size of the village by in excess of 40% based upon 2011 census figures, the continued absence of correspondence on this matter leads only to the conclusion of Judicial Review should the plan be found sound with BK3 is included.
Ultimately, removal of site BK3 from the Plan will not undermine the Local Plan’s spatial strategy, will not compromise the Council’s 5 year supply position, nor will it have any wider implications. There is therefore no reason for this site to remain in the Plan.
Site BK3 should be deleted and Barkway reinstated as a Category A Village. Retention of site BK3 within the Plan renders it unsound as it has not been positively prepared, and is not justified. The Local Plan is therefore in conflict with Paragraph 35 of the NPPF.

I wish to raise the following objections to Further Modifications in relation to site BK3.

NHDC made it very clear in their Hearing Statement of February 2021 (Matter 30) that Site BK3 should be deleted, and that there is no reasonable likelihood of the reserve school site being required during the plan period.

NHDC have also made their concerns very clear regarding integration of BK3 in urban design terms. Without the school site, the new housing will be divorced from the built form of the village. In response to Question 30.1(c), NHDC clearly stated that the allocation should be deleted as it is no longer justified or consistent with national policy.
The revised wording for policy BK3 includes a “contribution towards travel by sustainable modes of transport between Barley and Barkway schools” in attempt to justify the sustainability of 140 new homes. However, this relies on young children using a bus to access First School provision and brings into question the settlement hierarchy of the whole Plan. If it is considered sustainable to rely on a bus service for a 140 dwelling development, then this opens up a number of other opportunities for similar scale developments in villages that lack full First School provision. This is not justified within the settlement hierarchy and makes the Plan unsound.
Quite correctly, in response to Question 30.3, NHDC made it clear that Barkway should be a Category A village. Para 13.35 of the Submission Local Plan inc. Further Modifications accepts that ‘facilities are limited’ in the village. This paragraph also attempts to justify the scale of new development as a response to Barkway’s ‘development needs’. However, the specific ‘development need’ that the construction of 140 new dwellings would meet is not provided. Development of this magnitude and layout is wholly disproportionate to the scale and character of the village, which has evolved as a linear settlement.

The table submitted by NHDC in response to Question 30.4(c) clearly highlights the disproportionate allocation of new housing for Barkway compared to 2011 population figures and current school provision for other settlements. This is not sustainable.

It is unclear why the Inspector would retain Site BK3 within the Plan on the basis of the evidence submitted, and NHDC’s own request for deletion. No correspondence has been made public to justify this position. Numerous pieces of correspondence have been published relating to the deletion of site BK3 including an apparently unchallenged statement from NHDC establishing the correctitude of the process of its deletion. The resulting absence of transparency casts great doubt on the veracity of the examination. Viewed against the magnitude of the proposed development that would increase the size of the village by in excess of 40% based upon 2011 census figures, the continued absence of correspondence on this matter leads only to the conclusion of Judicial Review should the plan be found sound with BK3 is included.
Ultimately, removal of site BK3 from the Plan will not undermine the Local Plan’s spatial strategy, will not compromise the Council’s 5 year supply position, nor will it have any wider implications. There is therefore no reason for this site to remain in the Plan.
Site BK3 should be deleted and Barkway reinstated as a Category A Village. Retention of site BK3 within the Plan renders it unsound as it has not been positively prepared, and is not justified. The Local Plan is therefore in conflict with Paragraph 35 of the NPPF.

I wish to raise the following objections to Further Modifications in relation to site BK3.

NHDC made it very clear in their Hearing Statement of February 2021 (Matter 30) that Site BK3 should be deleted, and that there is no reasonable likelihood of the reserve school site being required during the plan period.

NHDC have also made their concerns very clear regarding integration of BK3 in urban design terms. Without the school site, the new housing will be divorced from the built form of the village. In response to Question 30.1(c), NHDC clearly stated that the allocation should be deleted as it is no longer justified or consistent with national policy.
The revised wording for policy BK3 includes a “contribution towards travel by sustainable modes of transport between Barley and Barkway schools” in attempt to justify the sustainability of 140 new homes. However, this relies on young children using a bus to access First School provision and brings into question the settlement hierarchy of the whole Plan. If it is considered sustainable to rely on a bus service for a 140 dwelling development, then this opens up a number of other opportunities for similar scale developments in villages that lack full First School provision. This is not justified within the settlement hierarchy and makes the Plan unsound.
Quite correctly, in response to Question 30.3, NHDC made it clear that Barkway should be a Category A village. Para 13.35 of the Submission Local Plan inc. Further Modifications accepts that ‘facilities are limited’ in the village. This paragraph also attempts to justify the scale of new development as a response to Barkway’s ‘development needs’. However, the specific ‘development need’ that the construction of 140 new dwellings would meet is not provided. Development of this magnitude and layout is wholly disproportionate to the scale and character of the village, which has evolved as a linear settlement.

The table submitted by NHDC in response to Question 30.4(c) clearly highlights the disproportionate allocation of new housing for Barkway compared to 2011 population figures and current school provision for other settlements. This is not sustainable.

It is unclear why the Inspector would retain Site BK3 within the Plan on the basis of the evidence submitted, and NHDC’s own request for deletion. No correspondence has been made public to justify this position. Numerous pieces of correspondence have been published relating to the deletion of site BK3 including an apparently unchallenged statement from NHDC establishing the correctitude of the process of its deletion. The resulting absence of transparency casts great doubt on the veracity of the examination. Viewed against the magnitude of the proposed development that would increase the size of the village by in excess of 40% based upon 2011 census figures, the continued absence of correspondence on this matter leads only to the conclusion of Judicial Review should the plan be found sound with BK3 is included.
Ultimately, removal of site BK3 from the Plan will not undermine the Local Plan’s spatial strategy, will not compromise the Council’s 5 year supply position, nor will it have any wider implications. There is therefore no reason for this site to remain in the Plan.
Site BK3 should be deleted and Barkway reinstated as a Category A Village. Retention of site BK3 within the Plan renders it unsound as it has not been positively prepared, and is not justified. The Local Plan is therefore in conflict with Paragraph 35 of the NPPF.

I wish to raise the following objections to Further Modifications in relation to site BK3.

NHDC made it very clear in their Hearing Statement of February 2021 (Matter 30) that Site BK3 should be deleted, and that there is no reasonable likelihood of the reserve school site being required during the plan period.

NHDC have also made their concerns very clear regarding integration of BK3 in urban design terms. Without the school site, the new housing will be divorced from the built form of the village. In response to Question 30.1(c), NHDC clearly stated that the allocation should be deleted as it is no longer justified or consistent with national policy.
The revised wording for policy BK3 includes a “contribution towards travel by sustainable modes of transport between Barley and Barkway schools” in attempt to justify the sustainability of 140 new homes. However, this relies on young children using a bus to access First School provision and brings into question the settlement hierarchy of the whole Plan. If it is considered sustainable to rely on a bus service for a 140 dwelling development, then this opens up a number of other opportunities for similar scale developments in villages that lack full First School provision. This is not justified within the settlement hierarchy and makes the Plan unsound.
Quite correctly, in response to Question 30.3, NHDC made it clear that Barkway should be a Category A village. Para 13.35 of the Submission Local Plan inc. Further Modifications accepts that ‘facilities are limited’ in the village. This paragraph also attempts to justify the scale of new development as a response to Barkway’s ‘development needs’. However, the specific ‘development need’ that the construction of 140 new dwellings would meet is not provided. Development of this magnitude and layout is wholly disproportionate to the scale and character of the village, which has evolved as a linear settlement.

The table submitted by NHDC in response to Question 30.4(c) clearly highlights the disproportionate allocation of new housing for Barkway compared to 2011 population figures and current school provision for other settlements. This is not sustainable.

It is unclear why the Inspector would retain Site BK3 within the Plan on the basis of the evidence submitted, and NHDC’s own request for deletion. No correspondence has been made public to justify this position. Numerous pieces of correspondence have been published relating to the deletion of site BK3 including an apparently unchallenged statement from NHDC establishing the correctitude of the process of its deletion. The resulting absence of transparency casts great doubt on the veracity of the examination. Viewed against the magnitude of the proposed development that would increase the size of the village by in excess of 40% based upon 2011 census figures, the continued absence of correspondence on this matter leads only to the conclusion of Judicial Review should the plan be found sound with BK3 is included.
Ultimately, removal of site BK3 from the Plan will not undermine the Local Plan’s spatial strategy, will not compromise the Council’s 5 year supply position, nor will it have any wider implications. There is therefore no reason for this site to remain in the Plan.
Site BK3 should be deleted and Barkway reinstated as a Category A Village. Retention of site BK3 within the Plan renders it unsound as it has not been positively prepared, and is not justified. The Local Plan is therefore in conflict with Paragraph 35 of the NPPF.

I wish to raise the following objections to Further Modifications in relation to site BK3.

NHDC made it very clear in their Hearing Statement of February 2021 (Matter 30) that Site BK3 should be deleted, and that there is no reasonable likelihood of the reserve school site being required during the plan period.

NHDC have also made their concerns very clear regarding integration of BK3 in urban design terms. Without the school site, the new housing will be divorced from the built form of the village. In response to Question 30.1(c), NHDC clearly stated that the allocation should be deleted as it is no longer justified or consistent with national policy.
The revised wording for policy BK3 includes a “contribution towards travel by sustainable modes of transport between Barley and Barkway schools” in attempt to justify the sustainability of 140 new homes. However, this relies on young children using a bus to access First School provision and brings into question the settlement hierarchy of the whole Plan. If it is considered sustainable to rely on a bus service for a 140 dwelling development, then this opens up a number of other opportunities for similar scale developments in villages that lack full First School provision. This is not justified within the settlement hierarchy and makes the Plan unsound.
Quite correctly, in response to Question 30.3, NHDC made it clear that Barkway should be a Category A village. Para 13.35 of the Submission Local Plan inc. Further Modifications accepts that ‘facilities are limited’ in the village. This paragraph also attempts to justify the scale of new development as a response to Barkway’s ‘development needs’. However, the specific ‘development need’ that the construction of 140 new dwellings would meet is not provided. Development of this magnitude and layout is wholly disproportionate to the scale and character of the village, which has evolved as a linear settlement.

The table submitted by NHDC in response to Question 30.4(c) clearly highlights the disproportionate allocation of new housing for Barkway compared to 2011 population figures and current school provision for other settlements. This is not sustainable.

It is unclear why the Inspector would retain Site BK3 within the Plan on the basis of the evidence submitted, and NHDC’s own request for deletion. No correspondence has been made public to justify this position. Numerous pieces of correspondence have been published relating to the deletion of site BK3 including an apparently unchallenged statement from NHDC establishing the correctitude of the process of its deletion. The resulting absence of transparency casts great doubt on the veracity of the examination. Viewed against the magnitude of the proposed development that would increase the size of the village by in excess of 40% based upon 2011 census figures, the continued absence of correspondence on this matter leads only to the conclusion of Judicial Review should the plan be found sound with BK3 is included.
Ultimately, removal of site BK3 from the Plan will not undermine the Local Plan’s spatial strategy, will not compromise the Council’s 5 year supply position, nor will it have any wider implications. There is therefore no reason for this site to remain in the Plan.
Site BK3 should be deleted and Barkway reinstated as a Category A Village. Retention of site BK3 within the Plan renders it unsound as it has not been positively prepared, and is not justified. The Local Plan is therefore in conflict with Paragraph 35 of the NPPF.