Comment

Representation ID: 59359

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/09: Larger Residential Development (10 or more units)

Part 1a – This criterion requires an appropriate housing mix. There is no evidence in the supporting text to set out what may be appropriate in Fulbourn to meet local needs. It remains unclear why at least 5% in the housing mix should be built to be accessible and adaptable dwellings M4(2) standard. This has not been justified. There is no information in the supporting text other than mention that the local residents think the needs of an ageing population should be considered. As this is for housing schemes of 10 or more units in order to achieve 5% of anything the scheme would have to be much more than 10 – (a development of 50 units to get 2.5 homes). How is this different from Policy H/9 in the Local Plan except it is requiring at least 5% but without clear justification.

Part 1b – We consider that this criterion simply repeats the Local Plan policy on affordable home (Policy H/10).

Part 2a - There is no information in the supporting text about a Building for a Healthy Life (BHL) assessment and where a developer could find out how to carry such an assessment out. Any appraisal system should be agreed with the local planning authority as the decision-making body.

We consider that the use of BHL toolkit should be used with caution as it does not provide absolute results on design quality. It is useful as an engagement tool or for discussion to agree on what the development should aim to achieve. It uses a traffic light system for 12 questions with the aim to score greens, reduce ambers and avoid reds. As the tool is for all development it is very difficult to differentiate in the document different responses to village/rural areas as compared to urban and could conflict with the objectives of neighbourhood plan. A reference to the VDG SPD would be more appropriate.

Part 2b – Written Ministerial Statement HCWS488 by the Secretary of State for Communities and Local Government dated 25 March 2015 states that “neighbourhood plans should not set ……….. any additional local technical standards or requirements relating to the construction, internal layout or performance of new dwellings.” It is not clear what this adds to the policies in the Local Plan about renewable energy - Policy CC/3 Renewable and Low Carbon Energy in New Developments. We adopted a new SPD in 2020 which we had suggested could be cross referenced in the supporting text about renewables - Greater Cambridge Design and Construction Supplementary Planning Document

Part 3a. – This appears to be a new criterion included in the Plan as previously there had not been mention of degradation of the natural wetland ecosystem.
Would this criterion be better place in Policy FUL/04?

Part 3b – This criterion repeats the policy included in the Local Plan – Policy CC/8: Sustainable Drainage Systems.

Part 3c – Does this criterion add any value as other policies within the Plan cover this issue – FUL/01; FUL/04.

Part 3d – This is repeating an existing policy in the Plan – FUL/03

Part 3e – This is repeating Policy FUL/01

Part 4 of the policy – We repeat the comments we made at Regulation 14 that developers can only be asked to contribute outside their site (i.e., in the Parish) through a Section 106 Planning Obligation and where the Government rules can be met. As noted in our comments above, they must be:
• necessary to make the development acceptable in planning terms;
• directly related to the development; and
• fairly and reasonably related in scale and kind to the development.
A developer could not be required to contribute to strengthen existing facilities for the village as a whole.

We remain unsure what is meant by ‘to support community integration in response to the requirements set out by Fulbourn Parish Council’ given that other statutory service providers will determine how their services are delivered. It is unclear whether this requirement is set out in the Plan and supported by evidence for such requirements There is a list on page 110 in the Delivery Priorities chapter of the Plan. How would a development know what is required or a planning officer know when it has been met? It is suggested that “in response to the requirements set out by Fulbourn Parish Council” is deleted from the policy.