Fulbourn Neighbourhood Plan - Submission version

Delete paragraph 2 of Policy FUL /01 since the reference to an Important Visual Gap designation duplicates other policy designations including the Green Belt. Reference to an Important Visual Gap policy and reference to it elsewhere in the document should be removed including Figure 8

Representations on behalf of Cambridgeshire & Peterborough NHS Foundation Trust to the Submitted version of the Fulbourn Neighbourhood Plan

Policy FUL/01 - "Protecting the Distinctiveness and Landscape Setting of Fulbourn"

Cambridgeshire & Peterborough NHS Foundation Trust are the freehold landowners of land at Fulbourn Hospital. This is the site currently occupied by a number of healthcare services and located to the west of Capital Park (referred to as the “former Fulbourn Hospital site”) within the Neighbourhood Plan)

Whilst supporting the publication of a draft Neighbourhood Plan, the Trust is needing to ensure that the policies and proposals within the document do not, as far as reasonably possible, hinder the delivery of vitally important healthcare services. The Trust at its heart must prioritise healthcare provision, an aspiration and objective brought more sharply into focus during the global pandemic.

Policy FUL/01 within the Draft Neighbourhood Plan relates to the setting of the village and its separation from the City. The policy contains six paragraphs of policy wording which seek to protect the distinctiveness and the landscape setting of the village.

The first paragraph is of a generic nature to protect and enhance the setting and special character of Fulbourn by ensuring that all development proposals should not have an adverse effect on the rural character and openness of the landscape setting. We would support such a statement having regard to planning policies which are positively written and which should not advocate poor or inappropriate development as a matter of course.

The second paragraph within the policy states that development will not be permitted which would encroach on or reduce the current dominant green aspect of the “Important Visual Gap between Fulbourn and the boundary of the urban area of Cambridge and neighbouring villages”. The Neighbourhood Plan has introduced this new “Important Visual Gap” policy approach which would appear to be a strategic policy which duplicates a number of other policies within national or local context.

The area that is the subject of the Important Visual Gap is shown in Figure 8 of the Neighbourhood Plan and correlates with an area of land already designated as Green Belt whose purposes are set out within national planning policy guidance in the NPPF at paragraph 138.

Paragraph 138 of the NPPF states :
“Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns; and
e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land.”

These Green Belt purposes in our view duplicate the Important Visual Gap proposal put forward in the Neighbourhood Plan and simply places another policy on top of an existing policy. Indeed, looking at the Important Visual Gap approach in more detail, it is directed to development which would “encroach on or reduce the current dominant green aspect of the Important Visual Gap” within that area. It suggests that development which would not encroach upon or reduce the green aspect would not be relevant in the context of this policy wording given this is the only reference to the Important Visual Gap in terms of policy wording.

In this context, the Trust has already made representations to the Greater Cambridge Local Plan Consultation documents to remove the current built up area of Fulbourn Hospital from the Green Belt on the basis of the nature and character of the built up form in that location does not fulfil Green Belt purposes. ( see enclosed) This is similarly the case with the intention of including Fulbourn Hospital within an Important Visual Gap policy which already duplicates other policies. Accordingly, the Trust do not support Policy FUL/01 having regard to the duplicating nature of the policy and the layer of further policy designations within the area.

It is the case that under the current regime of planning policies within the development plan , the Trust must on every occasion must make the case for Very Special Circumstances for building within the Green Belt. It is the Trust’s view that land which falls in the northern part of the Fulbourn Hospital site is of a character that it is no longer fulfilling a Green Belt function given its built form including land that has the benefit of planning permission (eg. the new Resource Centre granted planning permission in April 2021 (20/02887/FUL). Indeed in the current climate of significant pressure upon healthcare services and their effective and efficient delivery, it is vital that such planning constraints do not jeopardise forward looking plans to consolidate such critical and important facilities on the Fulbourn Hospital site .

Turning to Paragraphs 4 and 5 within Policy FUL/01, the text lists a number of identified “Locally Important Views” in Figure 9 of the Plan and then states development will not be permitted where it would adversely affect the setting of those views or the loss of woodland and openness. In the cases where development could proceed within those viewpoints and where it would not affect the views or the woodland or open areas (notwithstanding any other policy designations) then proposals would presumably not be considered relevant in the context of this part of the Policy.

As stated above it is the Trust’s view to establish a planning framework where it able to deliver new and improved healthcare services based around the existing built up area of the hospital. In the circumstances where such development would be consolidating the existing built form we would consider it would safeguard such viewpoints.

There is no merit, benefit or justification for defining a Local Green Space at "Fulbourn Hospital Parkland" as put forward with in Policy FUL/05 having regard to the existence of current policy designations such as the Green Belt and Conservation Area .

We respectfully suggest that reference to a Local Green Space at Fulbourn Hospital Parkland be removed from Policy FUL/05 of the Neighbourhood Plan.

Representations on behalf of Cambridgeshire & Peterborough NHS Foundation Trust to submitted draft Fulbourn Neighbourhood Plan

Cambridgeshire & Peterborough NHS Foundation Trust are the freehold landowners of land at Fulbourn Hospital. This is the site currently occupied by a number of healthcare services and located to the west of Capital Park (referred to as the “former Fulbourn Hospital site”) within the Neighbourhood Plan)

Whilst supporting the publication of a draft Neighbourhood Plan, the Trust is needing to ensure that the policies and proposals within the document do not, as far as reasonably possible, hinder the delivery of vitally important healthcare services. The Trust at its heart must prioritise healthcare provision, an aspiration and objective brought more sharply into focus during the global pandemic.

Fulbourn Policy FUL/05 – Local Green Space and Protected Village Amenity Areas

This policy seeks to identify Local Green Spaces within the Neighbourhood Plan Area. From the outset the Neighbourhood Plan acknowledges at Paragraph 8.1 that Local Green Space are intended to be protected from inappropriate development as intended by the policies protecting Green Belts. There is clearly a duplication in the instance where Green Belt designation applies and when the Neighbourhood Plan also seeks to identify land within the Green Belt as a Local Green Space. The definition of Green Belt and the reasoning for including land within it is already set out within national planning policy guidance and in the development plan as is the protection of those areas from inappropriate development.

We cannot see any justification for including Local Green Space designations within the existing Green Belt and in such a context , the Trust cannot support the identification of the “Fulbourn Hospital Parkland” in paragraph 1c of Policy FUL/05

The Trust has made representations to the emerging Greater Cambridge Local Plan to seek amendment to the Green Belt boundary to exclude a significant area of the Fulbourn Hospital site to be removed from the Green Belt on the basis of the significance of a large built footprint and the impact that this has and the justification for including the land within the Green Belt designation. (see enclosed) The Trust is also cognisant of the open parkland to the south of the site but at the same time is respectfully seeking clarity from the various authorities that in the circumstances where some development which need to take place which may encroach on part of this parkland area that further policy designations are not put in place to jeopardise the provision of appropriate healthcare services on this important campus.

The imposition of further policy designations on an area which has already been the focus of vitally important healthcare services will be resisted by the Trust whilst acknowledging the perceived importance of the hospital site by some in terms of the open land to the front of the site.

Clearly there is a subjective element of defining what area constitutes parkland and what does not. This is relevant to the situation at the Fulbourn Hospital site where the now demolished Kent House (demolished in 2008) covered a substantial land area to the west of Burnett House.

We note that the NPPF 2021 refers to Local Green Space (paras 102-103) . In such a context paragraph 103 states “Policies for managing development within a Local Green Space should be consistent with those for Green Belts.” We do see merit in identifying Local Green Spaces on land which is already Green Belt. We do not understand what benefits this would provide to the community on top of the Green Belt policy which already covers this parkland area as well as inclusion within the designated Conservation Area. From the Trust’s perspective it simply adds another policy restriction onto a site which remains absolutely key to the provision of critical new healthcare services.

The Trust must be a in position to be able to deliver healthcare services on this site and imposing additional planning designations across the whole of the defined Local Green Space area simply threatens the delivery of very important services that this site offers to the wider community.

Please see attached supporting documents.

Please see attached supporting documents.

I responded to the previous consultation on the Regulation 14 in March 2021. The plan itself still has a lot of positives in terms of surface water management, referencing the SCDC Local Plan, policies CC/8 and CC/9 and protecting the local watercourse networks.

I have had a look through the revisions made under the Regulation 16 and it may be that it has been decided not to include the recommendations, however I have reiterated the points raised below:

- Reference to the Cambridgeshire Flood and Water Supplementary Planning Document (SPD), which I have linked below for ease of reference, should be made regarding the principle of designing surface water drainage into a development. This document is adopted by South Cambridgeshire District Council
- SCDC Local Plan policy CC/7 is particularly important for protecting existing watercourses and groundwater bodies from pollution. It would be beneficial to include reference to this within the Neighbourhood Plan
- It would be worth drawing attention to Chapter 14 of the NPPF, as this relates to flood risk. For example paragraph 160(b) aims for development to be safe for the lifetime without increasing flood risk and where possible reducing flood risk overall
- With reference to the flood risk around Fulbourn, it is noted that this is made up mainly of surface water flood risk. There is some useful information on the gov.uk website on surface water flood risk, as well as in the South Cambridgeshire Strategic Flood Risk Assessment
- It would be good to include some policy directly related to the flood risk, drawn together from the policy within SCDC Local Plan, but relating to the risk around Fulbourn, particularly around water quality and quantity, to protect the chalk streams, and to ensure development does not increase flood risk within the village.

Surface water and sustainable drainage systems (SuDS) planning webpage: https://www.cambridgeshire.gov.uk/business/planning-and-development/flood-and-water/surface-water-and-sustainable-drainage-systems-suds-planning

Cambridgeshire Flood and Water SPD: https://www.cambridgeshire.gov.uk/asset-library/imported-assets/Cambridgeshire_Flood_and_Water_Suplementary_Planning_Document.pdf

Surface Water Drainage Guidance for Developers: https://www.cambridgeshire.gov.uk/asset-library/imported-assets/SWGFD%20FINAL%20-%20November%202019.pdf

Surface water flood maps: https://flood-warning-information.service.gov.uk/long-term-flood-risk/map

South Cambridgeshire Strategic Flood Risk Assessment: https://www.scambs.gov.uk/planning/local-plan-and-neighbourhood-planning/the-adopted-development-plan/stages-in-the-preparation-of-the-local-plan-2018/strategic-flood-risk-assessment-september-2010/

Happy to discuss anything of the above should you have any queries.