Chapter 5 Providing more housing
Object
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167636
Received: 19/03/2019
Respondent: Mr Peter Hewitt
Chapter 5 Does not take into account the 530 houses which have recently been granted planning permission when assessing the housing need and continues to promote houses when the need is for 1 and 2 bedroom flats. The location of the preferred rural exception sites is vague and hides that one of the sites is actually on the Flood Plain in contravention of Appendix C of the NP.
CHAPTER 5 COMMENTS
5.10 The AECOM report of 2017, predates the planning approvals which have subsequently been granted for some 530 homes. The 91 "affordable homes" identified in the AECOM report need to be adjusted to take account of the provisions for affordable homes which have been made as part of the 530 home planning approvals.
5.11 The "need" for 91 affordable homes is not justified due to the issues made in the discussion above. In addition to this the SEA produced by AECOM and published in Oct 2018, highlighted the need for 1 and 2 bedroom flats, but this has not been taken into account by the Parish Council, even though the SEA report postdates the 530 home planning permissions and contains more accurate data on the "need" in Cottenham.
"Meeting the need" Section
* The logic in this section is flawed as the conclusion reached in the later part of the segment are not based on the information provided at the beginning. In item 5.20 confirms the planning approvals for 530 homes and that the locally assessed objective was exceeded by more than 100 homes. Item 5.23 goes on to confirm that from the 520 homes 90 affordable homes would be made available as part of these planning permissions, meaning the AECOM 2017 assessment of 91 will have been met, this is particularly the case when the flats included in item 5.22 are taken into account.
* Item 5.24 the Parish Council make the statement that affordable homes are not locally affordable but provides no justification for why they disagree with the SCDC definition. The Parish Council provides no definition for what "locally affordable" means and given no opportunity for it to be debated.
* In item 5.25 SCDC identified 91 local households fall between local authority intervention and the ability to afford local homes at market rates. However, this does not define the ability of these local householders to afford, "affordable" homes and "locally affordable" homes. In item 5.26 it is stated that AECOMs assessed need is for 91 "locally affordable" homes, however the AECOM report does not use the term "locally affordable", in fact in the AECOM report summary table 39 the report says "...there is no requirement for the Cottenham neighbourhood plan to set its own policy in this area...".
* In summary a report that predates the recent 530 home planning permission should not be used to justify the conclusions of the housing need, unless it is updated by AECOM to take these planning permissions into account. If the AECOM report is not to be updated then the conclusions should take into account the recommendations of the more recent SEA to build 1 or 2 bed flats and prorate the 91 affordable home requirement to take into account people who can afford "affordable" homes and "locally affordable" homes.
Item 5.30, the consultation pre-dates the 530 home planning permissions and therefore does not take into consideration changes in Cottenham residents thoughts now that permission has already been granted for 530 new homes.
Page 39, COH 2-2b states, "Cottenham is particularly vulnerable to flood risk...", which raises the question why is one of the rural exception sites being promoted by the NP when it is actually on the flood plain. Not that any of this is readily apparent from the NP as actual details of the rural exception sites are almost entirely absent.
Page 41, COH 2-3, fig 14 underestimates the number of 1 or 2 bed flats could be built at these locations and therefore the contribution which could be made to the "locally affordable" need.
Page 43, COH 2-4, this has not been updated to take account of the 530 home planning permissions, which means the need for 225 homes identified in 2-4d has already been met, meaning this policy no longer has any justification.
General comment: whilst elsewhere in the NP significant detail is given for other proposed developments (Durman Stearn site for instance) with layout plans and location details, no such information is given for the Rural Exception sites. It is not possible to tell from the NP submitted to SCDC that one of the preferred sites (Broad Lane) is on the flood plain, which directly contradicts the appendix C Drainage and Flooding requirements. It also removes the ability for anybody commenting on the NP to comment directly on the individual rural exception sites, which seems odd given how important the rural exception sites are to the NP housing policy and in particular, given that approval of the NP would effectively give the Parish Council approval to develop the rural exception sites in accordance with Policy COH 2-4. This also hides the fact that to build the 91 "locally affordable" homes using the CLT model could lead to the need to build an additional 250 homes if the example of Stretham CLT is used as a guide, where two thirds market rate houses were needed to fund the one third affordable homes. It seems unlikely that the NP would get a warm welcome if it was known to be promoting 250 new homes in addition to the 530 home already granted planning permission.
Comment
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167641
Received: 14/02/2019
Respondent: Environment Agency
Applaud council's decision to seek Brownfield sites for development allocations. Clearly you are aware of the associated constraints.
Need to consider following:
* Flood Risk & Flood risk Assessments (FRA):
* Potential Ground Contamination:
* Surface Water drainage:
* Foul Water Drainage:
Object
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167646
Received: 22/03/2019
Respondent: Cambridgeshire County Council
Policy COH/2.1: Development Framework
Seeking an amendment to Policy COH/1-7 and COH/2-1 to facilitate the provision of primary education facilities in the village.
Object
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167647
Received: 25/03/2019
Respondent: Southern & Regional Developments
Agent: Claremont Planning Consultancy Ltd
The policy approach of the Neighbourhood Plan for housing delivery and the identification of sites for residential development is unsound.
Object
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167649
Received: 25/03/2019
Respondent: Southern & Regional Developments
Agent: Claremont Planning Consultancy Ltd
Policy COH/2-1: Development Framework
The proposed development framework of Cottenham does not take into account defensible features and assets. The site at Broad Lane should be included.
Object
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167650
Received: 25/03/2019
Respondent: Southern & Regional Developments
Agent: Claremont Planning Consultancy Ltd
Policy COH/2-2 Large site design
The Neighbourhood Plan should not overly constrain the delivery of important large sites through stringent policy requirements.
Object
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167651
Received: 25/03/2019
Respondent: Southern & Regional Developments
Agent: Claremont Planning Consultancy Ltd
Housing sites being proposed by landowner for inclusion in the neighbourhood plan in the Broad Lane area.
1. Land north of Kingfisher Way
2 Land off Kingfisher Way
3. Land west of Broad Lane
Concern that the plan is not meeting housing need for Cottenham. Sites were assessed for housing by AECOM during plan making.
Comment
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167655
Received: 25/03/2019
Respondent: Gladman Developments
Support Parish Council (PC) commissioning AECOM to undertake housing needs assessment. Question why PC 'corrects' AECOM scenarios to take account of local constraints recognised in Local Plan to provide a 'more realistic constrained number'. Evidence provided by AECOM identifies housing need figure up to 716 dwellings over plan period.
Local Plan elevates Cottenham from Minor Rural Centre to Rural Centre recognising sustainability credentials of Cottenham. PC should not be seeking to restrict level of growth to this settlement. Plan should take a positive approach to growth in this sustainable location.
Object
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167658
Received: 25/03/2019
Respondent: Gladman Developments
Policy COH/1-5 Village Character - New Build
Support use of term 'where practical' as this adds element of flexibility within policy wording. Essential that criteria list is not too prescriptive resulting in hindering delivery of development opportunity.
Part b) - too prescriptive and should be removed
Part f) - requirement not supported by any evidence. Too prescriptive as it will not allow most appropriate layout of schemes.
Part i) - admirable aim but aspirational. Clarity on how this is to be delivered. Delivery of communication infrastructure is responsibility of telecommunication and broadband industry. Policy requirement may have unintended impact on housing delivery as delivery of this infrastructure outside control of developer.
Object
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167660
Received: 25/03/2019
Respondent: Gladman Developments
Policy COH/2-1 Development Framework
Object to use of 'countryside policies' which seek to protect countryside for sake of its intrinsic character. Based on old PPS7 approach - restrictive stance to rural development. NPPF clear presumption in favour of sustainable development. Use of frameworks creates presumption against development in all areas beyond an arbitrary line - confines physical growth of settlement. Contrary to basic conditions.
Wording of policy should be modified to allow for flexibility. Suggest having criteria based policy in Plan.
Object
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167661
Received: 25/03/2019
Respondent: Gladman Developments
Policy COH/2-2 Large Site Design
Welcomes use of term where practicable as this provides degree of flexibility.
Concern that some of the requirements are ambiguous and subjective - e.g. 'applying imaginative and original design'. This type of design policy should be more guidance rather than actual policy.
Part b) requires schemes apply landscape design criteria but unclear what this criteria requires - need for further detail in policy or its supporting text.
Object
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167662
Received: 25/03/2019
Respondent: Gladman Developments
Policy COH/2-3 Use of Brownfield Sites for Housing
Support principle of policy.
Despite concerns raised in previous representations does not appear that Parish Council has provided certainty that these allocations are available for development. Without this detailed level of understanding regarding deliverability of these sites they are merely aspirations which should be included as appendix to Plan which contains other non land use policies.
Object
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167663
Received: 25/03/2019
Respondent: Gladman Developments
Policy COH/2-4 Locally Affordable Housing and CLT
Whilst recognising importance of delivering housing to meet identified housing needs rural exception housing can be difficult to deliver if they are to provide 100% affordable housing - unlikely that landowner of development would be willing to promote such a scheme as it is highly doubtful that it will be viable and achieve the most optimum value of land that could be secured.
Recommend that in order to secure affordable housing needs in full consideration should be given to additional housing allocations to provide mix of market and affordable homes to meet affordable housing need in full
Object
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167666
Received: 25/03/2019
Respondent: This Land
Agent: Bidwells
Policy COH/2.1 Development Framework
Support principle of policy. This Land concerned with site D in Figure 15. However as still in discussions with Parish Council regarding detailed layout of housing development - these are not fixed so need for flexibility. May need to modify development framework boundary to facilitate delivery of housing alongside securing improvements to configuration of sports space and community facilities.
Suggested wording to policy.
Comment
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167678
Received: 25/03/2019
Respondent: South Cambridgeshire District Council
Policy COH/2-1: Development Frameworks
SCDC considers that the Local Plan policy that designates a Development Framework is a strategic policy and that amendments to the development framework of a village is not one for a neighbourhood plan to include. Changes to a framework boundary to reflect current and future proposed growth on the edge of a village will be considered in a future review of the Local Plan
Comment
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167679
Received: 25/03/2019
Respondent: South Cambridgeshire District Council
Policy COH/2-2: Large Site Design
Whilst welcoming aim of policy to provide design guidance for large sites in Cottenham, there are criteria that identify locally specific requirements without providing justification for them
i. Criterion c) relates to play space - LEAP which is different from requirement in Local Plan - Policy SC/7: Outdoor Play Space, Informal Open Space and New Developments and Figure 10 which provides a guide for the on-site provision of open space. This criterion could result in development having a lesser provision of open space - is this intention of policy?
ii. Criterion d) relates to distribution of affordable houses. In Local Plan Policy H/10 for affordable housing it mentions that this sort of housing should be in small groups or clusters distributed throughout the site. It is not clear that there is locally supported evidence to support neighbourhood plan approach to have individual affordable houses pepper potted through a site?
Comment
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167680
Received: 25/03/2019
Respondent: South Cambridgeshire District Council
Policy COH/2-3: Use of brownfield sites for housing
a) SCDC considers that this policy would seem to repeat the site-specific policies for these three sites and it is not sure what the policy adds to the Plan?
b)The total housing potential in the table (page 41) is 24. If Durman and Watson's site come forward first with a total of 15 then is it the intention of the Plan that the Co-op site cannot provide any housing as it would be in excess of the 15 total specified in the policy.
c)As this is a policy allocating sites, it is unusual for two figures to be identified in a policy to show the location of any sites. Neither maps shows clearly the boundary of the three sites and are at too small a scale. If Figure 4 is the Site Specific Policies Map for the Plan then we recommend this should be referred to in the policy.
Comment
Cottenham Neighbourhood Plan - submission consultation
Representation ID: 167681
Received: 25/03/2019
Respondent: South Cambridgeshire District Council
Policy COH/2-4: Locally affordable housing and CLT
We feel that this policy could be misinterpreted to imply that it is promoting housing development in the open countryside. In criterion a) it states that homes are located on sites near or immediately adjacent to Cottenham's development framework boundary. We feel that the term "near" would need to be defined very precisely. Developers could see this as an opportunity to propose sites well away from the existing built area of the village of Cottenham which would be contrary to national and local plan policy. Would a preferable term be 'adjoining' to the framework? This would conform to the wording in the Local Plan policy on rural exception sites (Policy H/11)