Barkway Parish Council's Response to NHDC's Local Plan 2011-2031
Barkway Parish Council
Strategic Planning and Projects Group,
North Hertfordshire District Council,
PO Box 480,
M33 0DE.
25/11/16
Dear Sir/Madam
North Herts District Council Proposed Submission Local Plan 2011 – 2013
We wish to make the following representation.
We apologise for the requirement to make this representation by this means, however we found the online software recommended by NHDC to be unreliable, possibly due to the internet connection currently available to us.
We believe the plan has been positively prepared, is justified and will be effective. However we do not believe the following paragraph is consistent with National Planning Policies under the National Planning Policy framework, and thus renders the plan not sound.
This Parish Council objects to Local Plan Proposed Submission Paragraph 13.37, in particular with respect to land ref BK3 and we request that this site be removed from the plan.
The NPPF clearly states the “presumption in favour of sustainable development”.
This Parish Council does not believe that site BK3, when combined with sites BK1 and BK2 within the village of Barkway, is sustainable and is contrary to several paragraphs of the National Planning Policy Framework and contradicts North Hertfordshire District Councils own policies.
Executive Summary
Barkway is an ancient linear village sited along the B1368 at the end of the Chiltern ridge. In 2011 it comprised 329 dwellings. Since then 31 homes have been given planning permission or completed. They have been designed in sympathy with local styles. [Proposed Submission Local Plan p.144] Barkway has few amenities, requiring private vehicular travel to access any shops, medical, dental and middle/secondary school facilities. It has a minimal bus service that provides a poor connection to neighbouring towns, resulting in the need for an average car ownership of one per adult. Our emerging Neighbourhood Plan responses indicated an average car ownership of two per household.
NHDC has proposed the allocation of three sites at the north-end of the village, as per Appendix A
BK1 - 13 dwellings
BK2 - 20 dwellings
BK3 -140 dwellings
BK3 is wholly disproportionate in size to the existing village and, with BK1 & 2, will lead to a major increase in the use of private vehicles.
In all other previous drafts of the Proposed Submission Local Plan (PSLP), site BK3 has been excluded or rejected on the same grounds as we will demonstrate.
Errors in the PSLP.
Para 13.37 - BK1 incorrectly states the northern boundary requires appropriate treatment to maintain integrity of Barkway Bridleway 017. This should read Barkway Bridleway 018.
Para 13.37 -BK3 incorrectly names Barkway Bridleway 017 as Barkway Footpath 017.
Para 13.38 states Barkway has a soft furnishings business. This has not been the case since 2012.
NPPF Para 14 Presumption in favour of sustainable development.
The benefit of new homes on site BK 3 must demonstrably outweigh their adverse effect.
BK3 is a proposed development that is on the edge of the current village development boundary. It is still separate from the main village and its very design makes it an insular development which is likely not to encourage integration with the rest of the community. Barkway is a small village of approx. 330 dwellings with no shop, doctors or schooling for children beyond year 4 (age 9). This would mean travelling a minimum of 2.5 miles for the nearest small convenience store, doctors and even further for Higher education, larger shops etc. There is a limited bus service but no safe well-lit pathways or cycle ways connecting the village to other local villages or towns. The size of this disproportionate development will overwhelm the village, changing it negatively rather than enhancing it. There are no proposals to improve the infrastructure or local amenities. Whilst the PSLP proposes the provision of a shop, there is no guarantee a developer would include this in any development, and NHDC cannot provide any evidence that the business would be sustainable. The addition of a further 173 houses at the north end of the village, in addition to those already built or for which planning has been granted since 2011, will create an increase of 62% in the village size, which is disproportionate and inappropriate.
This additionally contradicts Proposed Submission Local Plan Section 3.7, Strategic Objectives, ECON6, which states, Sustain the vitality of our villages and the rural economy in supporting rural diversification whilst ensuring development is of an appropriate scale and character.
We will further demonstrate the unsustainability of this site as follows:
NPPF Para 11 & 109 - Conserving and enhancing the natural environment.
NPPF Para 112 Agricultural land use.
NPPF Para 125 Impact of light pollution.
Site BK3 is Grade II agricultural land, and some of the most versatile in our district, whilst elsewhere in the district, agricultural land of lower grade on the edge of better resourced villages, has been discounted from the Proposed Submission Local Plan.
BK3 is on the Chiltern Ridge.
The soil grading has consistently been stated as a reason for discounting this site in previous draft Proposed Submission Local Plans. Whilst part of this site has lain fallow for a number of years due to an absent landowner, the largest portion of the site on the west side has been successfully and profitably farmed, and contributed to the nation’s food supply for as long as living memory.
NHDC has, within the Proposed Submission Local Plan (para 4.150) highlighted the need to protect the East Anglian Heights which includes the Chiltern Ridge. In proposing site BK3, NHDC contradicts its own policy of protecting this area, instead proposing housing, with associated street-lighting on the ridge itself, which would be visible for some 30 miles to the north.
The eastern edge of BK3 is a well-known roosting place for the common (endangered) pipistrelle bats. The entire site of BK3 is a wildlife corridor, used by local herds of fallow deer which cross from Cokenach Estate, through the northern edge of BK3, across Royston Road and thereafter onto Reed and other areas. The eastern half of BK3 is a regular shelter and grazing area for the whole herd.
These are also in contradiction to NHDC Proposed Submission Local Plan Para 3.3 Spatial strategy. Which states:
3.3 Our spatial strategy is one of promoting sustainable development by supporting the use of suitably located previously developed land and buildings and by focusing the majority of development on our towns (including urban extensions) in order to make maximum use of existing facilities, social networks and infrastructure, and maximise opportunities to deliver new infrastructure. It also allows for some growth of our villages in order to allow those communities to continue to thrive.
and Proposed Submission Local Plan para 11.62 which states [plans should] emphasise the importance of natural networks of linked habitat corridors to allow the movement of species between suitable habitats and promote biodiversity.
We further wish to refer to NHDC landscape Character Assessment for Area 230 Barkway – (Appendix B)
This states the importance of Barkway for pipistrelle and brown long-eared bats, known to be present in the BK3 area, as supported by AGB Environmental , Extended Phase 1 Habitat Survey, for land within BK3. (page 15 - Appendix C)
Moreover, the Landscape Character Assessment stresses that the Barkway Plateau is of moderate landscape value, and should be improved and conserved.
It states that, for large urban extensions and new settlements of greater than 5 ha, this type of development would be inappropriate within this character area, due to its rural and small scale nature. It would introduce elements that would alter the character and affect the existing key characteristics such as the historic ribbon development form and the small scale regular patter of field boundaries. Extensive development could disrupt the rights of way (bridleways 017 and 018) and could reduce accessibility to the countryside.
In addition, it states that major transport improvements would not be appropriate in this area.
This document supports both the Parish Council and the responses to our emerging Neighbourhood Plan that the area could support carefully located and designed small scale developments such as those offered by BK1 and BK2.
Additionally, we refer to Appendix D – Special Projects - Chalk East – Chalk landscape from the East of England Geodiversity Partnership.
Within this document, the importance of the Chiltern Ridge/ East Anglian Heights is further reinforced, stating: “The Chalk is the 'backbone' of the physical landscape in the East of England. It forms a ‘chalk belt’ which crosses the region, including the northern Chiltern hills and their north-eastwards extension as the East Anglian Heights, and continuing through West Suffolk into Breckland and West Norfolk. It forms some of the most beautiful and inspiring landscapes in the region”, and directly indicates this in the main photograph header which shows the view of the Chiltern Ridge looking south towards Barkway. BK3 is on the extreme left of the photograph, on the ridge, demonstrating its exposed location.
NPPF Para 17 Core Planning principles
Amongst the 12 principles of this policy, there is a clear indication that planning should be plan-led and empower local people to shape their surroundings, with succinct local and neighbourhood plans setting out a positive vision for the area.
In addition to the above; there is a clear contradiction to Proposed Submission Local Plan Chapter 4 – Strategic policies, Policy SP1 – Sustainable Development
Barkway and Nuthampstead Designated Areas emerging Neighbourhood Plan has been rejected twice by NHDC due to the constant changings of the guidelines, we understand is once again under review (LAIS 1394 Neighbourhood Planning Bill). At no time has NHDC therefore considered the expressed wish and will of the community, laid out in the draft supported by extensive questionnaire responses (Appendix E)
The Plan is under a third re-write to bring it in line with the current legislation, and expected to be submitted to NHDC in spring 2017.
Para 17 also states [planning shall] “take account of the different roles and character of different areas, promoting the vitality of our main urban areas, protecting the Green Belts around them, recognising the intrinsic character and beauty of the countryside and supporting thriving rural communities within it”
“contribute to conserving and enhancing the natural environment and reducing pollution. Allocations of land for development should prefer land of lesser environmental value, where consistent with other policies in this Framework”.
As stated above, the development of BK 3 would detract from the intrinsic character and beauty of the country side, and remove valuable agricultural land from the food supply chain permanently
Additionally, Para 17 states planning should “support the transition to a low carbon future in a changing climate” and “actively manage patterns of growth to make the fullest possible use of public transport, walking and cycling, and focus significant development in locations which are or can be made sustainable”
We shall demonstrate that far from supporting this, the inclusion of BK3 shall in fact increase the carbon footprint of our community due to the dependency on private vehicles and the lack of immediate employment within walking or cycling distance of the site, without any provision for improvement to our infrastructure, public transport or road network.
In addition to the above; there is a clear contradiction to Proposed Submission Local Plan Chapter 4 – Strategic policies, Policy SP1 – Sustainable Development.
NPPF Para 28. Creation of employment and prosperity.
Plans should “support the sustainable growth and expansion of all types of business and enterprise in rural areas, both through conversion of existing buildings and well-designed new buildings; promote the development and diversification of agricultural and other land-based rural businesses”
No evidence has been provided by NHDC that the inclusion of Site BK3 will create, beyond the building phase, any new employment will be created to match the amount of committed and proposed housing development. This was a major decisive factor in the dismissal of an appeal under the Town And Country Planning Act 1980, reference 13/04975/OUT by the Secretary of State on 12/9/2016 ( Appendix F)
NDHC planning officers have failed to recognise the significance of the location to Newsells Park. Newsells Park Thoroughbred Stud farm is the largest employer in the village, offering much valued employment to approx. 30-35 local people. NHDC refer to this as a parkland estate, failing to recognise this is in fact a thriving stud farm, who have great concerns over their viability to operate should BK3 be developed. This is due to the location of the site, immediately adjacent to the only land on the estate, with soft premium land, suitable for the grazing and paddocking of their young foals. The disruption to their business by development of BK3 is thought to be considerable, due to noise, the proximity of homes and human beings to the grazing land, and the risk to the foals from curious persons and dogs straying onto their land.
This is in clear contradiction to Proposed Submission Local Plan paragraph 4.35
Beyond our main towns, there is a steady demand for rural employment land and premises. Owing to the size and extensive spread of rural settlements these types of development are best dealt with on a case-by-case basis rather than through allocations, although our general approach will be to direct concentrations of rural business to the Category A villages. There are quite sizeable employment sites in villages such as Ashwell, Codicote, Kimpton, Little Wymondley and Weston which provide rural jobs and should be retained.
There is much evidence that BK3 development will contravene many of the NPPF policies on Sustainable Transport as listed below:
NPPF Para 30 Promoting Sustainable transport
This paragraph emphasis that planning shoul:
· “Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion. In preparing Proposed Submission Local Plans, local planning authorities should therefore support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport.
· Plans and decisions should take account of whether:
· the opportunities for sustainable transport modes have been taken up depending on the nature and location of the site, to reduce the need for major transport infrastructure;
· Improvements can be undertaken within the transport network that cost effectively limit the significant impacts of the development. Development should only be prevented or refused on transport grounds where the residual cumulative impacts of development are severe.”
NPPF Para 34 states:
“Plans and decisions should ensure developments that generate significant movement are located where the need to travel will be minimised and the use of sustainable transport modes can be maximised”.
NPPF Para 35 states:
Plans should protect and exploit opportunities for the use of sustainable transport modes for the movement of goods or people. Therefore, developments should be located and designed where practical to
● accommodate the efficient delivery of goods and supplies;
● give priority to pedestrian and cycle movements, and have access to high quality public transport facilities;
● create safe and secure layouts which minimise conflicts between traffic and cyclists or pedestrians, avoiding street clutter and where appropriate establishing home zones;
● incorporate facilities for charging plug-in and other ultra-low emission vehicles; and
● consider the needs of people with disabilities by all modes of transport
NPPF Para 37 Planning policies should aim for a balance of land uses within their area so that people can be encouraged to minimise journey lengths for employment, shopping, leisure, education and other activities.
Additionally, Proposed Submission Local Plan 3.7 Strategic Objectives, ECON7 Improve access opportunities, minimise the need to travel, and encourage journeys to be made by sustainable means of transport to ease congestion, reduce carbon emissions and the impacts on air quality management areas.
NPPF Para 95 – the move to low carbon future
The village of Barkway is 4 miles from the nearest town of Royston. It has a minimal rural bus service leaving the village at 0702, 0839, 0959 and 1159 in the morning. The earliest bus produces a poor connection to the railway station, meaning it is not possible to use it to catch trains to connect conveniently to either London or Cambridge for work. The afternoon and evening return service is equally as limited to just 4 buses between 1230 and 1830. Despite the increase in the population, through recent expansion of nearby Buntingford, also serviced by this route, there has been no increase in the bus service.
The bus stop is located on Royston Road, which has no pavements to connect to the site on the western edge. There are no streetlights. This therefore would create a situation where pedestrians are forced to walk on the highway.
As a result, residents in the village are wholly dependent on the use of private motor vehicles for transport in and out of the village.
As stated previously. Barkway is extremely restricted in terms of amenities, and it is necessary to travel to access shops, doctors’ surgeries, dentists, and middle and secondary schools etc. Car ownership remains on average at 2 per household, and peaks at 1 per adult as confirmed by our draft Neighbourhood Plan.
The nearest amenities are in the village of Barley some 2 miles away, where there is a village shop with post office, a further filling station, garage and doctors’ surgery. It is noted that the Proposed Submission Local Plan states.
Proposed Submission Local Plan Para 13.44 That (even) whilst Barley is smaller than the neighbouring village of Barkway, it does have a wider range of facilities attracting visitors from both Barkway and other nearby settlements. However, for many requirements residents visit the nearby town of Royston.
This is an acknowledgement that Barkway is extremely limited for amenities and is dependent on the need to travel (by private transport) to access amenities.
NHDC has provided no evidence that there will be any enhancement of public (sustainable) transport, or any improvement in the minor roads that provide the connection to the main trunk road (A10) to Royston or Buntingford, to access amenities. This is in contradiction to Proposed Submission Local Plan 3.7 Strategic Objectives Econ 8 - Ensure 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.
These minor (unclassified roads) are narrow, and in some places too narrow to allow vehicles to pass without the use of informal passing places.
Cycling is considered by our community to be unsafe due to the poor road surface, undulating roads and blind summits as supported by Transport Planning Associates, Technical note (Appendix G) As a result and we are not aware of any one person in our community who cycles to or from either Royston or Buntingford as a result.
NHDC have provided no evidence that jobs will be created on site BK3, and therefore it must be presumed that a high proportion of homeowners on the site will be required to use private vehicles to commute to work, schools and access amenities, thereby creating increased traffic movements on our already under-resourced infrastructure.
Site BK3, with 140 homes, is therefore likely to create up to an additional 280 private vehicles and a considerable increase in traffic movements, as supported by our independent consultation (Appendix G)
Site BK3 is clearly therefore in contradiction to, and contravenes a number of key NPPF policies in terms of its ability to meet the requirements for sustainable transport.
NPPF Para 38 states that “Where practical, particularly within large-scale developments, key facilities such as primary schools and local shops should be located within walking distance of most properties”
Whilst no convenience or food shop exists within Barkway, and NHDC have provided no evidence that a developer would be required or willing to provide a shop on site BK3, or that it would be sustainable, or sufficiently large to permit a weekly shop, there is a clear contravention to this policy. Even were a shop was to be provided, due to the historic linear nature of the village, visitors to the shop would be dependent on the use of private cars to access it.
Additionally, whilst Barkway does have a primary school, consideration must be given to the fact that, from either side of site BK 3 there is no street lighting between the site and the primary school, or continuous pavements, to provide a safe “walk to school”.
NPPF Para 55 Enhance or maintain the vitality of rural communities.
As the site is detached from the central position of the main village, it is our and that of our community’s belief that site BK3 will create a satellite village, resulting in minimum integration. It will be a disproportionate “estate” bolted on to the end of the village and detract from its historic linear character.
This is again in conflict with Proposed Submission Local Plan Para 3.6 Spatial Vision, [the aspiration is that:] New development will have contributed to the creation of sustainable communities. These are safe, attractive and inclusive; well-integrated into settlements; respect local distinctiveness; raise the standards of sustainable design and architectural quality; make a positive contribution to the local area; and ensure the protection, restoration and enhancement of valuable natural and historic resources and
Additionally, this is in direct contradiction to Proposed Submission Local Plan 3.7 Strategic Objectives Policy ENV1 Direct development towards the most sustainable locations which seek to maintain the existing settlement pattern.
NPPF Para 72 – Education
The government places great importance to ensuring sufficient school places are available.
Whilst Barkway Voluntary Aided First School has capacity for additional pupils, all other children above the age of 9 will be required to travel to Royston, or Buntingford for middle or secondary education. Currently due to the extensive development of both of these towns, schools are oversubscribed. Whilst transport is available to Greenway School in Royston – the village’s current feed-in school. Greenway School is over-subscribed, and transport to the alternative school, Roysia is not provided free of charge, but at a cost of £1200 per pupil per annum. There is no guarantee of a place on the coach if the subscription for Greenway places fills it. As a result, parents are dependent on the use of private cars to transport their children to school on economic grounds. These middle schools feed into Meridian Secondary School. NHDC have provided no evidence to improve transport to school or to create increased school places, for the additional middle and secondary school pupils arising from BK3, therefore it must be assumed that there will be an increased dependency on the need to travel by private car to schools.
Other evidence outside the direct scope of the NPPF –
Reed planning decision
We would refer you to Appendix H Appeal Decision APP/X1925/A/14/2218194
This planning application, on its third appeal, was dismissed. It parallels directly the proposal to develop site BK3, creating a detached development, on the edge of a village, with no footpath connection, and a heavy reliance on private transport.
Braughing Planning Decision - Appendix I Appeal Decision APP/J1915/W/15/3004594
This application bore may similarities to BK3 and was dismissed on very similar ground to those which we have demonstrated.
Summary
It is the belief of Barkway Parish Council and that of our community, that the inclusion of site BK3 in the Proposed Submission Local Plan would represent an inappropriate level of growth for the village and is in conflict with our emerging development strategy for the village. It is in contradiction to multiple policies within the National Planning Policy Framework, and would create a non-sustainable development, with negative impact on the environment, delivering inappropriately located new homes, far outweighing their benefit.
To make the plan “sound” in this respect, we would expect to see Site BK3 removed from the plan, whilst retaining sites BK1 and 2, which we believe are sustainable and fall within our emerging Neighbourhood Plan and development strategy.
We would be willing to appear before the Inspector if as and when required, during the examination process.
Yours faithfully
On behalf of Barkway Parish Council
The Reverend Councillor, Sonia Falaschi-Ray
Chairman
Councillor Dr Bob Davidson
Appendices
A-Map of Proposed sites
B -Landscape Character Assessment
C - AGB Environmental Extended Phase 1 Habitat Survey
D - Geo East Special Projects – Chalk Landscapes
E - Barkway Parish Council – Draft Neighbourhood Plan Public Consultation summary
F- Town and Planning Act 1990 Section 78 Appeal by Charles Church Severn Valley and Edward Ware Homes LTD on Residual Land at Cappards Road, Bishop Sutton Application Ref 13/04975/OUT
G – Transport Planning Associates Transport Assessment for Barkway Parish Council
H – Reed Planning- Appeal Decision APP/X1925/A/14/2218194
I – Braughing Planning Appeal Decision APP/J1915/W/15/3004594
