Draft Policy S&GS 17 sets out the overarching policy to ensure new developments positively contribute to sustainable growth in the local area through the provision of new and improved community infrastructure, in line with local priorities. We welcome supporting paragraph 9.6 which states new development must address arising needs for specific infrastructure, including for healthcare. Health infrastructure is clearly identified as a priority, with an expectation that development proposals must make provision to meet healthcare infrastructure costs made necessary by the development.

Supporting paragraphs 9.19 to 9.22 sets out the Council’s assumptions on the growth in demand for healthcare infrastructure in the local area, partly through the use of proxy data (Paragraph 9.19). NHSPS are supportive of the work the Council has undertaken thus far in exploring options to mitigate impact on healthcare infrastructure based on forms of population growth assumptions. In line with our previous response at Regulation 14 Stage (April 2024) however, we continue to recommend that the Council engage with Cambridgeshire and Peterborough ICS (C&P ICS) to ensure the most appropriate and suitable form of mitigation is identified in the area.

Healthcare providers should have flexibility in determining the most appropriate means of meeting the relevant healthcare needs arising from a new development. Where new development creates a demand for health services that cannot be supported by incremental extension or internal modification of existing facilities, this means the provision of new purpose-built healthcare infrastructure will be required to provide sustainable health services. Options should enable financial contributions, new-on-site healthcare infrastructure, free land/infrastructure/property, or a combination of these. It should be emphasised that the NHS and its partners will need to work with the Council in the formulation of appropriate mitigation measures.

Shelford Health Centre
NHSPS own the freehold to Shelford Health Centre (“the Site”), a site map of this is attached in Appendix 1 of the supporting letter.

We note that the Council has undertaken an exercise in exploring options for the Site’s redevelopment within supporting paragraph 9.23. In line with the above, any quantum or retained and/or re-provided health or other community uses would need to be determined by the local health commissioners (the Integrated Care Board) – including that required for continued health services, and any part of the Site which may no longer be needed for the delivery of health services (and therefore available for alternative uses).

Local health commissioners are best placed to determine the means and form of mitigation to meet the healthcare needs of the local community, including when considering the expansion of facilities to increase the level of provision. As such, we recommend the Council engage in consultation with the ICB when determining forms of healthcare infrastructure provision.

Full objection sent by email and attached for Grange Field reference number 40128

INTRODUCTION
Carter Jonas has been instructed by Axis Land Partnerships Ltd (Axis) to respond to the Reg.16 consultation for the submission draft Stapleford & Great Shelford Neighbourhood Plan (draft S&GSNP). Axis has an interest in land within the Neighbourhood Plan area.

In summary, the Axis representations to draft S&GSNP are as follows:
• Comment on the Policy Context section of draft S&GSNP to highlight those development plan documents that are not referred to (Cambridge Southern Fringe AAP), to identify relevant emerging development plan and policy documents (emerging Greater Cambridge Local Plan), and revised national policy (NPPF December 2024).
• Comment on the housing and affordable housing references in the Vision for draft S&GSNP, which would not be addressed by the lack of policy support in the document for additional housing.
• Comment on those objectives of draft S&GSNP related to development because they are unlikely to be delivered without any support for additional residential development.
• Object to Policy S&GS 12 because it does not take into account that the land between Stapleford and Great Shelford and Cambridge is already designated as Green Belt.
• Object to Policy S&GS 13 because the proposed important views from Stapleford Cemetery (View T) and Gog Magog Way (View U) (as shown on Map 7 and described in Appendix 7) are general views of the countryside rather than a notable view of a particular feature from a public footpath or vantage point.
• Comment on Policy S&GS 17 because draft S&GSNP does not support new development that might enable the delivery of new community infrastructure.
• Object to Policy S&GS 19 because it is inconsistent with and duplicates transport policy requirements in the adopted South Cambridgeshire Local Plan and revised NPPF December 2024.
• Object to Policy S&GS 21 because the proposed Improved Landscape Area designation (as shown on Map 14) is inconsistent with and duplicates a similar countryside enhancement designation in the adopted Cambridge Southern Fringe AAP.

The draft S&GSNP will need to be in general conformity with strategic policies in the adopted South Cambridgeshire Local Plan. It is acknowledged that the Local Plan does not allow for the release of land from the Green Belt around Stapleford or Great Shelford through the neighbourhood plan process.

In due course draft S&GSNP will be examined by an Independent Examiner who will determine whether the basic conditions for a neighbourhood plan have been met. As explained in this response, it is considered that some of the policies and designations in draft S&GSNP do not meet Basic Condition (a) and are inconsistent with national policy, or Basic Condition (e) and are not in general conformity with the strategic policies contained in the development plan for the area.

At the end of the representations to each policy is a summary and the requested changes.

All references to the NPPF in these representations relate to the December 2023 version unless otherwise stated because of the transitional arrangements for neighbourhood plans contained in Paragraph 239 of the December 2024 NPPF.


REPRESENTATIONS TO DRAFT S&GSNP

Policy Context

COMMENT

Paragraphs 3.2 to 3.5 of draft S&GSNP seeks to identify the policy context for the document. It is considered that this section covers only part of the relevant policy context, and omits references to other development plan documents, to emerging development plan documents, and to national policy. This is relevant because some policies in draft S&GSNP are inconsistent with adopted and emerging development plan policies and with national policies, as set out in these representations. Those inconsistencies might not have occurred if the policy context section had provided a more comprehensive review of adopted and emerging policy.

The policy context section does not identify the adopted Cambridge Southern Fringe AAP as a relevant development plan document for draft S&GSNP. As set out in the representations to Policy S&GS 12 and Policy S&GS 21, the proposed Improved Landscape Area duplicates similar policies in the Cambridge Southern Fringe AAP but does not mention the important connection between the delivery of countryside enhancements and development contained in the AAP.

The policy context section refers to the Green Belt and highlights the extent of the Green Belt around the villages and between the villages and Cambridge. The policy section does not refer to national policy relating to the Green Belt as contained in Chapter 13 of the NPPF. As set out in the representations to Policy S&GS 12, the adopted Local Plan and the NPPF already provide strong protection from development for land located within the Green Belt, and it is unnecessary for draft S&GSNP to include similar policies to these areas.

Paragraph 3.5 provides some limited commentary on the emerging Greater Cambridge Local Plan, but other matters should have been included too. Stapleford and Great Shelford will continue to be classified as Rural Centres in the settlement hierarchy for the emerging Local Plan. The status of these villages in the settlement hierarchy reflects the good range of services and facilities within them. The emerging Local Plan identifies these villages within a new Rural Southern Cluster which seeks to connect employment growth to housing in an accessible location. The Rural Southern Cluster approach reflects the close proximity of the villages to employment including Cambridge Biomedical Campus, and the availability of a railway station, bus services and cycle routes from the villages, and the transport improvements to be delivered by the planned Cambridge South East Transport Project in the future.

The emerging Local Plan will need to be consistent with the changes to national policy contained in the revised NPPF published in December 2024. Those changes include a higher housing need figure for both Cambridge and South Cambridgeshire, that development needs should be met in full, and where exceptional circumstances exist to review and release land from the Green Belt to meet those development needs in sustainable locations. In addition, the Government has recently confirmed a commitment to further growth in the Oxford to Cambridge corridor. It is very likely that the development strategy in the emerging Greater Cambridge Local Plan will need to be updated to reflect changes to national policy and growth aspirations, and this is likely to affect land within the draft S&GSNP area.

It is considered that a more comprehensive review of the relevant policy context for draft S&GSNP would have highlighted that some policies and designations are not required.

Summary Representation
Paragraphs 3.2 to 3.5 of draft S&GSNP provide only part of the relevant policy context. The adopted Cambridge Southern Fringe AAP should be identified as a relevant development plan document. The policy context should include more detailed commentary on the emerging Greater Cambridge Local Plan and national policy. It is considered that a more comprehensive review of the relevant policy context for draft S&GSNP would have highlighted that some policies and designations are not required.

Requested Change
It is requested that the policy context section in draft S&GSNP refers to the adopted Cambridge Southern Fringe AAP and includes more detailed commentary on the emerging Greater Cambridge Local Plan and national policy.

Vision

COMMENT

The Vision for draft S&GSNP refers to addressing identified housing and affordable housing needs. The Housing Needs Assessment (AECOM March 2023) identified a high need for both social rent and affordable home ownership housing in the villages. It should be noted that affordable housing is mostly delivered in conjunction with market housing, and that rural exception schemes are typically small scale and provide a limited number of dwellings. The affordable housing requirement in the South Cambridgeshire Local Plan is for 40% of housing to be affordable from developments of 10 or more dwellings. As such, sufficient land to provide both market and affordable housing would need to be allocated to meet the identified affordable housing needs.

It would be appropriate for the Vision to seek to address those housing needs. However, as set out in this response, the draft S&GSNP does not provide any policy support for housing and affordable housing needs to be addressed through the emerging Greater Cambridge Local Plan. It appears that draft S&GSNP seeks to introduce new policy designations that are clearly intended to limit development at the villages in the future, and to restrict potential options for the growth of the villages. It is unlikely that the aspirations in the Vision to address housing and affordable housing need would be achieved without positive policy support in draft S&GSNP to actually meet those needs.

Draft S&GSNP should include an additional policy that supports the allocation of land for development at the villages through the emerging Greater Cambridge Local Plan process to meet housing and affordable housing needs.

Summary Representations
It is unlikely that the aspirations in the Vision to address housing and affordable housing need would be achieved without positive policy support in draft S&GSNP to actually meet those needs.

Requested Change
No changes are requested to the Vision.


Objectives

COMMENT

Paragraph 5.2 identifies 10 theme-based objectives for draft S&GSNP. These objectives are appropriate. It is noted that the objectives related to housing, biodiversity, community amenities and infrastructure, and countryside enhancement all refer to development, and it is assumed that additional development is necessary to support the delivery of those objectives. However, draft S&GSNP does not allocate any land for development and does not provide any policy support for development to be brought forward in the future through the emerging Greater Cambridge Local Plan process.

Draft S&GSNP should include a policy that supports the allocation of land for development at the villages through the emerging Greater Cambridge Local Plan process to deliver the housing, biodiversity, community amenities and infrastructure, and countryside enhancement related objectives.

Summary Representation
It is unlikely that those objectives that are associated with the delivery of additional development - housing, biodiversity, community amenities and infrastructure, and countryside enhancement - would be achieved without specific policy support for development.

Requested Change
No changes are requested to the objectives.


Policy S&GS 12: Protecting and Enhancing Stapleford and Great Shelford’s Landscape Character

OBJECT

Policy S&GS 12 relates to landscape character. Criteria 1(b) of this policy seeks to retain the existing area of separation between Stapleford and Great Shelford and the City of Cambridge. Criteria 4 of this policy refers to development affecting the proposed Landscape Improvement Area in Policy S&GS 21. In summary, these criteria do not take into account that all of the land between the villages and Cambridge is already designated as Green Belt, or that a Countryside Enhancement Strategy is identified in the adopted Cambridge Southern Fringe AAP.

Policy S/4 of the adopted South Cambridgeshire Local Plan seeks to maintain a Green Belt around Cambridge, with any development proposals in the Green Belt assessed against national policies contained in the NPPF. The Green Belt at Great Shelford and Stapleford is defined on the Local Plan Proposals Map Inset No.45. Stapleford Allotments fall within the land designated as Green Belt. As highlighted in Paragraph 142 of the NPPF, openness is identified as an essential characteristic of the Green Belt. Policy NH/2 of the adopted South Cambridgeshire Local Plan seeks to protect and enhance landscape character, and refers to National Character Areas. Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”.

Criteria 1(b) of Policy S&GS 12 would duplicate the openness requirement of the Green Belt designation that already applies to land between the villages and Cambridge, and landscape character is already protected by Policy NH/2 of the adopted Local Plan. It is not necessary to duplicate development plan policies and national policies, and to do so would be inconsistent with Paragraph 16(f) of the NPPF. Therefore, criteria 1(b) of Policy S&GS 12 would not meet Basic Condition (a). In addition, it is not clear what is meant by the term “existing area of separation” between the villages and Cambridge, as it is not defined in draft S&GSNP.

As set out below in the representations to Policy S&GS 21, the proposed Improved Landscape Area duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP. The countryside enhancement strategy proposed in the adopted AAP are linked to and funded by development. There are no development allocations in draft S&GSNP that would support the delivery of the proposed Improved Landscape Area in Policy S&GS 21. As also requested in representations to Policy S&GS 21, the proposed Improved Landscape Area referred to in criteria 4 should be deleted, because it is inconsistent with and duplicates an adopted development plan policy which is contrary to national policy and would not meet Basic Condition (a).

Summary Representation
The reference in Criteria 1(b) of Policy S&GS 12 to retain the existing area of separation between the villages and Cambridge is not necessary because this area is already designated as Green Belt. Criteria 1(b) should be deleted.

The proposed Improved Landscape Area, referred to in Criteria 4 of Policy S&GS 12, duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP. Criteria 4 should be deleted.

Requested Change
It is requested that criteria 1(b) and criteria 4 of Policy S&GS 12 are deleted.


Policy S&GS 13: Important Views

OBJECT

Policy S&GS 13 identifies a number of proposed important views around the villages, which are to be maintained and enhanced as part of any development proposals. Those proposed important views are listed in Policy S&GS 13, shown on Map 7, and described in Appendix 7. It is noted that the majority of land at the edge of the villages fall within a proposed important view.

Axis’ land interest falls within the following identified views: New countryside park between Haverhill Road and Hinton Way (View O); Gap between 27 and 31 Mingle Lane (View S); Stapleford Cemetery (View T); and from Gog Magog Way (View U).

Axis has instructed The Landscape Partnership to provide an independent
appraisal of the identified Important Views O, S, T and U. The Landscape Rebuttal Statement is provided in Appendix A. The Visualisations of those Important Views is provided in Appendix B.

In summary, it is concluded in the Rebuttal Statement that no clear methodology has been provided with Policy S&GS 13 as to how the Important Views have been identified and what, if any, qualities they need to have to qualify. There is no public footpath or bridleway across the land off Hinton Way, and there are no public footpaths or bridleways within the proposed important views at Views O, S, T and U. The proposed important views at Views O, S, T and U do not take into account the changes to landscape and visual character that are taking place as a result of the retirement village development and associated countryside park at land of Haverhill Road, which is currently under construction. The proposed important views at Views O, S, T and U do not take into account the future potential changes to landscape and visual character that are likely to arise from the Cambridge South East Transport project (a new busway to the east of Stapleford with stops at Haverhill Road and Hinton Way), or the draft allocation for residential development off Mingle Lane in the emerging Greater Cambridge Local Plan (draft Policy S/RSC/HW for 100 dwellings).

Paragraph 041 (Ref ID: 41) of the Planning Practice Guidance states that “It [neighbourhood plan policies] should be concise, precise and supported by appropriate evidence”. The evidence put forward to explain and justify the proposed important views at Views O, S, T and U is not robust, and as such these proposed designations do not have regard to national policy and would not meet Basic Condition (a). It is considered that Views O, S, T and U are general views of the countryside, and typical of other similar views on the edge of villages elsewhere in South Cambridgeshire.

Policy NH/2 of the adopted South Cambridgeshire Local Plan seeks to protect landscape character and the landscape of the National Character Areas. Policy HQ1 identifies the design principles for development, which includes preserve and enhancing the character of the area and responding to the site context in the wider landscape (criteria a) and providing high quality landscape (criteria m). Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. The landscape character around the villages, and at Views O, S, T and U, is already protected by Policy NH/2, and high quality landscaping is required by Policy HQ1 of the adopted Local Plan. It is not necessary to duplicate development plan policies related to protecting landscape character, and to do so would be inconsistent with Paragraph 16(f) of the NPPF and would not meet Basic Condition (a).

It might be helpful for the Neighbourhood Plan Group to review the Examiner’s Report for the Fulbourn Neighbourhood Plan (published April 2022), which also considered proposed locally important views for that document - see Paragraphs 7.33 to 7.35. In summary, the draft Fulbourn Neighbourhood Plan identified multiple viewpoints into and out of the village that should be protected. The Examiner concluded that those proposed viewpoints were general in nature, the importance of those views to the surrounding landscape was not explained, and the relationship between the views and the settlement was not identified. The Examiner recommended that all of the proposed locally important viewpoints be deleted. It is suggested that the outcome should be the same for the proposed important views identified in Policy S&GS13, including Views O, S, T and U.

It is noted that no other made neighbourhood plans in South Cambridgeshire include a policy to protect identified views. A consistent approach should be applied for all neighbourhood plans within the same district.

Summary Representation
The proposed important views at Views O, S, T, and U are general views of the countryside only, do not contain any particularly notable landscape or topographic features, and the assessment of those views does not explain why those views are important to warrant special protection. The adopted South Cambridgeshire Local Plan already contains policies that seek to protect landscape character and policies that require high quality landscaping to be provided with development proposals, and it is not necessary to duplicate those policies in draft S&GSNP. It is requested that proposed Views O, S, T and U are deleted.

Requested Change
It is requested that the proposed important views at New countryside park between Haverhill Road and Hinton Way (View O), Gap between 27 and 31 Mingle Lane (View S); Stapleford Cemetery (View T), and from Gog Magog Way (View U) are deleted from Policy S&GS13 and from Map 7, and that references to these views are removed from Appendix 7.


Policy S&GS 17: Delivering Community Infrastructure Priorities Alongside New Development

COMMENT

Policy S&GS 17 relates to the delivery of community infrastructure through planning obligations, and identifies a specific need for informal open space and play space.
Policy TI/8 of the adopted South Cambridgeshire Local Plan seeks planning obligations from development for the delivery of necessary infrastructure. Paragraph 57 of the NPPF sets out the three tests for planning obligations. Section ID.23b of the Planning Practice Guidance provides further national guidance on planning obligations. As set out in Paragraph 16(f) of the NPPF, it is not necessary for neighbourhood plans to duplicate development plan policies or national policies, and therefore it is suggested that the first part of Policy S&GS 17 relating to planning obligations could be deleted.

Criteria 3 of Policy S&GS 17 appears to imply that the community infrastructure necessary to support a development is provided on that development site. The CIL Regulations, the supporting text to Policy TI/8 of the adopted South Cambridgeshire Local Plan, and Section ID.23b of the Planning Practice Guidance all allow for planning obligations to be pooled to meet strategic requirements and for obligations to be spent on off-site infrastructure projects. Criteria 3 of Policy S&GS 17 is inconsistent with regulations, national policy and development plan policy, and should be amended or deleted.

Criteria (a) of Paragraph 97 of the NPPF requires planning policies to plan positively for the provision of community facilities including open space. Policy S&GS 17 of draft S&GSNP identifies a need for informal open space and play space as a priority. However, as noted elsewhere in this response, draft S&GSNP does not provide any policy support for residential development that might deliver planning obligations for new community infrastructure. Policy S&GS 17 identifies community infrastructure needs, but does not explain how that infrastructure would actually be delivered without support from additional development. It is considered that Policy S&GS 17 would be ineffective at delivering community infrastructure in the absence of development or specific policy support for additional development, and it is likely that the identified needs for informal open space and play space would remain undelivered which would be a negative outcome. For these reasons, Policy S&GS 17 is inconsistent with Paragraph 97(a) of the NPPF, and as such would not meet Basic Condition (a).

Summary Representation
It is not necessary for Policy S&GS 17 to duplicate development plan policies or national policies relating to planning obligations. The first part of Policy S&GS 17 relating to planning obligations could be deleted.

Criteria 3 of Policy S&GS 17 is inconsistent with regulations, national policy and development plan policy, in respect of pooled and off-site contributions, and should be deleted.

Policy S&GS 17 would be ineffective at delivering community infrastructure in the absence of development or specific policy support for additional development. The identified needs for informal open space and play space would remain undelivered, which would be an outcome that is inconsistent with national policy.

Requested Change
It is requested that the first part of Policy S&GS 17 relating to planning obligations for community infrastructure is reviewed in order to determine whether it is necessary to duplicate adopted development plan policies and national policy for these matters.

It is requested that Criteria 3 of Policy S&GS 17 is deleted.

The references to identified needs for informal open space and play space should be retained in Policy S&GS 17, but it is requested that the policy includes a mechanism for the delivery of these community infrastructure items.

Draft S&GSNP should include policy support for additional development that could support the delivery of community infrastructure.


Policy S&GS 19: Managing the impacts of new development in the Plan area with respect to the movement of people and vehicles

Policy S&GS 19 of draft S&GSNP sets out the policy requirements for developments that have an impact on traffic. Policy TI/2 of the adopted South Cambridgeshire Local Plan deals with similar transport matters, including mitigating transport and environmental impacts. However, Policy TI/2 also refers to document requirements to identify transport impacts and sustainable transport options to address impacts. Chapter 13 of the NPPF and Section Id.42 of the Planning Practice Guidance provide detailed policy requirements for assessing the transport impacts of development. Paragraph 115 of NPPF 2023 (and Paragraph 116 of NPPF 2024) states that development should only be refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.

Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. It is considered that Policy S&GS 19 duplicates parts of Policy TI/2 of the Local Plan and parts of national policy on sustainable transport contained in Chapter 13 of the NPPF, which is not necessary. Policy S&GS 19 does not mention sustainable transport options to address transport impacts, and is inconsistent with Policy TI/2 and Paragraphs 109, 114 and 116 of the NPPF. Policy S&GS 19 is inconsistent with Paragraph 115 of the NPPF in terms of the highway impacts being severe. Policy S&GS 19 would be contrary to national policy, and as such would not meet Basic Condition (a). It is requested that Policy S&GS 19 is deleted or amended to be consistent with development plan policy and national policy on transport matters.

Summary Representation
Policy S&GS 19 duplicates development plan policies and national policies on transport, and would be inconsistent with Paragraph 115 of the NPPF, both of which would be contrary to national policy and would not meet Basic Condition (a).

Requested Change
It is requested that Policy S&GS 19 is deleted or amended to be consistent with development plan policy and national policy on transport matters.


Policy S&GS 21: Delivering Stapleford and Great Shelford’s Improved Landscape Area

OBJECT

Policy S&GS 21 of draft S&GSNP seeks to designate all of the land on the eastern edge of Stapleford and Great Shelford as an Improved Landscape Area, for the purpose of countryside enhancement measures. The proposed Improved Landscape Area is shown on Map 14.

Policy CSF/5 of the adopted Cambridge Southern Fringe AAP, which is part of the adopted development plan for South Cambridgeshire, already designates the same land for a countryside enhancement strategy. The land designated by Policy CSF/5 is shown on Inset E of the adopted AAP. Policy CSF/5 provides additional detail of the landscape, planting and access measures required. The countryside enhancement strategy proposed in the adopted AAP are linked to and funded by development. There are no development allocations in draft S&GSNP that would support the delivery of the proposed Improved Landscape Area in Policy S&GS 21, and without an effective delivery mechanism this proposed designation would not be implemented. The fact that the proposed Improved Landscape Area is unrelated to development and contains no delivery mechanism makes it inconsistent with Policy CSF/5 in the adopted Cambridge Southern Fringe AAP.

Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. It is clear that the proposed Improved Landscape Area designation in Policy S&GS 20 duplicates Policy CSF/5 of the adopted Cambridge Southern Fringe AAP, which is not necessary. Policy S&GS 21 would be contrary to national policy, and as such would not meet Basic Condition (a).

The second paragraph of Policy S&GS 21 requires planning obligations for landscape initiatives listed in Paragraph 11.32. Most of the listed landscape improvements are located on private land, and some are related to specific development proposals. It is not clear whether there is landowner agreement for these landscape improvements, and how they would be delivered on private land that is unrelated to a particular development. The landscape improvements for a particular development should be determined in a site specific policy for an allocation and at planning application stage, and contributions should not be sought for potentially unrelated landscape projects. The second paragraph of Policy S&GS 21 is not consistent with national policy on planning obligations contained in Paragraph 57 of the NPPF. In addition, Paragraph 10.46 provides the supporting text to Policy TI/2 of the adopted South Cambridgeshire Local Plan, and identifies landscaping and the historic landscape as matters where planning contributions may be required. It is not necessary for Policy S&GS 21 to also seek contributions towards landscape improvements. Therefore, the second paragraph of Policy S&GS 21 would be contrary to national policy, and as such would not meet Basic Condition (a).

Summary Representation
The proposed Improved Landscape Area duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP. It is requested that the proposed Improved Landscape Area in Policy S&GS 21 and shown on Map 14 is deleted.

The planning obligations for landscape initiatives referred to in Policy S&GS 21 and listed in Paragraph 11.32 are mostly unrelated to development and delivery is uncertain when it involves unrelated private land. It is requested that the second paragraph of Policy S&GS 21 is deleted.

Requested Change
It is requested that the proposed Improved Landscape Area in Policy S&GS 21, and shown on Map 14, is deleted.

It is requested that the second paragraph of Policy S&GS 21 is deleted.

INTRODUCTION
We have been instructed by Cambridgeshire County Council, as landowner, to respond to the Reg.16 consultation for the submission draft Stapleford & Great Shelford Neighbourhood Plan (draft S&GSNP). Cambridgeshire County Council owns the land allocated in the adopted South Cambridgeshire Local Plan for an extension to Cambridge Biomedical Campus – Policy E/2. As set out in these representations, there are policies and designations in draft S&GSNP that are not in general conformity with and undermine this allocation, and are inconsistent with national policy.

In summary, Cambridgeshire County Council’s representations to draft S&GSNP are as follows:
• Comment on the Policy Context section of draft S&GSNP to highlight those development plan documents that are not referred to (Cambridge Southern Fringe AAP), to identify relevant emerging development plan and policy documents (emerging Greater Cambridge Local Plan and draft Cambridge Biomedical Campus SPD), and revised national policy (NPPF December 2024).
• Object to Policy S&GS 12 (Protecting and Enhancing Stapleford and Great Shelford’s Landscape Character) because it does not take into account the allocation for an extension to Cambridge Biomedical Campus in the adopted South Cambridgeshire Local Plan, or that all of the land between Stapleford and Great Shelford and Cambridge is already designated as Green Belt.
• Object to Policy S&GS 13 (Important Views) because View K (DNA Path next to bridge over railway) and View P (High point on Granhams Road) are general views of the countryside and do not contain any notable landscape features, Policy E/2 includes landscape requirements for the extension to the Biomedical Campus, and Policies NH/2 and HQ1 of the adopted South Cambridgeshire Local Plan already protect landscape character and the character of areas in the wider landscape.
• Object to Policy S&GS 21 (Delivering Stapleford and Great Shelford’s Improved Landscape Area) because it is not in general conformity with and undermines the allocation for an extension to Cambridge Biomedical Campus in Policy E/2 of the adopted South Cambridgeshire Local Plan, and the land included within this proposed designation is already identified as an area for a Countryside Enhancement Strategy under Policy CSF/5 of the adopted Cambridge Southern Fringe AAP which remains part of the development plan and should not be duplicated.

In due course draft S&GSNP will be examined by an Independent Examiner who will determine whether the basic conditions for a neighbourhood plan have been met. As explained in this response, it is considered that some of the policies and designations in draft S&GSNP do not meet Basic Condition (a) and are inconsistent with national policy, or Basic Condition (e) and are not in general conformity with the strategic policies contained in the development plan for the area.

At the end of the representations to each policy is a summary and the requested changes.

REPRESENTATIONS TO DRAFT S&GSNP

Policy Context

COMMENT

Paragraphs 3.2 to 3.5 of draft S&GSNP seeks to identify the policy context for the document. It is considered that this section covers only part of the relevant policy context, and omits references to other development plan documents, to emerging development plan and policy documents, and to national policy. This is relevant because some policies in draft S&GSNP are inconsistent with adopted and emerging development plan policies and with national policies, as set out in these representations. Those inconsistencies might not have occurred if the policy context section had provided a more comprehensive review of adopted and emerging policy.

The policy context section identifies Policy E/2 in the adopted South Cambridgeshire Local Plan for an extension to Cambridge Biomedical Campus, and refers to some of the criteria contained in the adopted policy, but not all. Criteria (e) and criteria (h) to Policy E/2, not referred to in the policy context, are relevant to the representations to Policy S&GS 21. It is noted that Map 14, which is related to Policy S&GS 21, incorrectly includes the land allocated for an extension to the Cambridge Biomedical Campus within the proposed Improved Landscape Area. The full text of Policy E2 is provided in Appendix A of these representations, and the associated Proposals Map (Inset E South of Addenbrookes) is provided in Appendix B.


The policy context section does not identify the adopted Cambridge Southern Fringe AAP as a relevant development plan document for draft S&GSNP. As set out in the representations to Policy S&GS 12 and Policy S&GS 21, the proposed Improved Landscape Area duplicates similar policies in the Cambridge Southern Fringe AAP but does not mention the important connection between countryside enhancements and development contained in the AAP.

The policy context section refers to the Green Belt and highlights the extent of the Green Belt around the villages and between the villages and Cambridge. The policy section does not refer to national policy relating to the Green Belt as contained in Chapter 13 of the NPPF. As set out in the representations to Policy S&GS 12, the adopted Local Plan and the NPPF already provide strong protection from development for land located within the Green Belt, and it is unnecessary for draft S&GSNP to include similar policies to these areas.

Paragraph 3.5 of the policy context section refers to the emerging Greater Cambridge Local Plan. The draft S&GSNP refers to a preferred allocation within the plan area. However, it does not mention the preferred allocation immediately adjacent to the northern edge of the plan area boundary adjacent to Cambridge Biomedical Campus - Policy S/CBC Cambridge Biomedical Campus (including Addenbrooke’s Hospital). The full text and plans relating to emerging Policy S/CBC are provided in Appendix C. This preferred allocation is relevant to the representations to Policy S&GS 12 and Policy S&GS 13.

Greater Cambridge Shared Planning Service has recently consulted on a draft Cambridge Biomedical Campus SPD, which has been prepared in the context of adopted Policy E/2 and emerging Policy S/CBC. The draft SPD outlines some development principles for the expansion of Cambridge Biomedical Campus, including principles for design, landscape and open space. The draft SPD is not mentioned in the policy context section of draft S&GSNP. The draft SPD is relevant to the representations to Policy S&GS 12 and Policy S&GS 13.

It is considered that a more comprehensive review of the relevant policy context for draft S&GSNP would have highlighted that some policies and designations are not required.

Summary Representation
Paragraphs 3.2 to 3.5 of draft S&GSNP provide only part of the relevant policy context. The adopted Cambridge Southern Fringe AAP should be identified as a relevant development plan document. Policy E/2 in the adopted South Cambridgeshire Local Plan, Policy S/CBC in the emerging Greater Cambridge Local Plan, and the Green Belt policy in the NPPF should be referenced in more detail. The draft Cambridge Biomedical Campus SPD should be referenced as relevant policy guidance. A more comprehensive review of the relevant policy context for draft S&GSNP would have highlighted that some policies and designations are not required.

Requested Change
It is requested that the policy context section in draft S&GSNP refers to the adopted Cambridge Southern Fringe AAP and draft Cambridge Biomedical Campus SPD, and refers to additional policy requirements from Policy E/2 in the adopted South Cambridgeshire Local Plan, Policy S/CBC in the emerging Greater Cambridge Local Plan, and Chapter 13 in the NPPF.


Policy S&GS 12: Protecting and Enhancing Stapleford and Great Shelford’s Landscape Character

OBJECT

Policy S&GS 12 relates to landscape character. Criteria 1(b) of this policy seeks to retain the existing area of separation between Stapleford and Great Shelford and the City of Cambridge. Criteria 4 of this policy refers to development affecting the proposed Landscape Improvement Area in Policy S&GS 21. In summary, these criteria do not take into account the allocation for an extension to Cambridge Biomedical Campus in the adopted South Cambridgeshire Local Plan, that all of the land between the villages and Cambridge is already designated as Green Belt, or that a Countryside Enhancement Strategy is identified in the adopted Cambridge Southern Fringe AAP.

Policy E/2 in the adopted South Cambridgeshire Local Plan allocates land for an extension to Cambridge Biomedical Campus, which is located on the edge of Cambridge and within the northern boundary of the draft S&GSNP Area. The full text of Policy E2 is provided in Appendix A of these representations, and the associated Proposals Map (Inset E South of Addenbrookes) is provided in Appendix B. Policy E/2 is a strategic policy as set out in Appendix E of the adopted Local Plan. Policy S/CBC in the emerging Greater Cambridge Local Plan identifies a preferred allocation for an additional extension to Cambridge Biomedical Campus, which is located beyond and adjacent to the northern boundary of the draft S&GSNP Area. The full text and plans relating to emerging Policy S/CBC are provided in Appendix C. No planning applications have been submitted for either the adopted or emerging allocations at Cambridge Biomedical Campus. However, these two allocations would both reduce the separation between the villages and Cambridge. Criteria 1(b) of Policy S&GSNP is not in general conformity with Policy E/2 in the adopted South Cambridgeshire Local Plan, and as such does not meet Basic Condition (e).

Policy S/4 of the adopted South Cambridgeshire Local Plan seeks to maintain a Green Belt around Cambridge, with any development proposals in the Green Belt assessed against national policies contained in the NPPF. The Green Belt at Great Shelford and Stapleford is defined on the Local Plan Proposals Map Inset No.45. As highlighted in Paragraph 142 of the NPPF, openness is identified as an essential characteristic of the Green Belt. Policy NH/2 of the adopted South Cambridgeshire Local Plan seeks to protect and enhance landscape character, and refers to National Character Areas. Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. Criteria 1(b) of Policy S&GS 12 would duplicate the openness requirement of the Green Belt designation that already applies to land between the villages and Cambridge, and landscape character is already protected by Policy NH/2 of the adopted Local Plan. It is not necessary to duplicate development plan policies and national policies, and to do so would be inconsistent with Paragraph 16(f) of the NPPF. It is considered that, criteria 1(b) of Policy S&GS 12 is not consistent with national policy, and as such would not meet Basic Condition (a).

As set out below in the representations to Policy S&GS 21, the proposed Improved Landscape Area as currently defined in Map 14 of draft S&GSNP incorrectly includes the land allocated for an extension to Cambridge Biomedical Campus in Policy E/2 of the adopted Local Plan. The proposed Improved Landscape Area designation duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP. As requested in the representations to Policy S&GS 12, the proposed Improved Landscape Area should as a minimum exclude the land allocated for an extension to Cambridge Biomedical Campus, but preferably should be deleted entirely. As set out in the representations to Policy S&GS 12, the proposed Landscape Improvement Area is not in general conformity with Policy E/2 in the adopted Local Plan and as such does not meet Basic Condition (e), and duplicates Policy CSF/5 of the adopted Cambridge Southern Fringe AAP and as such would not meet Basic Condition (a).

Summary Representation
The reference in Criteria 1(b) of Policy S&GS 12 to retain the existing area of separation between the villages and Cambridge is inconsistent with the adopted and emerging allocations for extensions to Cambridge Biomedical Campus, and is not necessary because this area is already designated as Green Belt. Criteria 1(b) should be deleted.

The proposed Improved Landscape Area, referred to in Criteria 4 of Policy S&GS 12, duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP. Criteria 4 should be deleted.

Requested Change
It is requested that criteria 1(b) and criteria 4 of Policy S&GS 12 are deleted.


Policy S&GS 13: Important Views

OBJECT

Policy S&GS 13 identifies a number of proposed important views around the villages, which are to be maintained and enhanced as part of any development proposals. Those proposed important views are listed in Policy S&GS 13, shown on Map 7, and described in Appendix 7. It is noted that the majority of land at the edge of the villages fall within a proposed important view.

Cambridgeshire County Council owns two parcels of land within the proposed important views. One parcel of land is allocated in the adopted South Cambridgeshire Local Plan for an extension to Cambridge Biomedical Campus (Policy E/2) – see plan in Appendix B. The second parcel of land is identified as a preferred allocation for an additional extension to the Campus in the emerging Greater Cambridge Local Plan (Policy S/CBC) – see plan within Appendix C. These two parcels of land fall within View K (DNA Path next to bridge over railway) and View P (High point on Granhams Road). In summary, it is considered that proposed View K and View P are general views of the countryside only, do not contain any particularly notable landscape or topographic features, and the assessment of those views does not explain why those views are important to warrant special protection. There are other adopted development plan policies that would ensure the delivery of appropriate landscaping with development.

Appendix 7 of draft S&GSNP describes the proposed important views at View K and View P, and seeks to explain why those views should be protected. The photographs of View K and View P show a typical view of the countryside at these locations, containing agricultural land, hedgerows and trees, and areas of woodland. There are no notable key landscape or topographic features within those views to identify them as particularly important or as a defining characteristic of the adjacent villages. It is noted that the viewpoints for View K and View P are not from the edge of the villages and are not in the direction of the villages. The commentary for View K and View P in Appendix 7 of draft S&GSNP and the assessment of LCA B2 (Hobsons Brook and Ninewells arable lowland) in the Stapleford & Great Shelford Landscape Character Assessment (October 2019) does not identify any key landscape features or provide the evidence to justify why these views are sufficiently important to warrant special policy protection. The commentary for LCA B2 identifies Cambridge University Hospitals and Cambridge Biomedical Campus as visually dominant features of this area. Paragraph 041 (Ref ID: 41) of the Planning Practice Guidance states that “It [neighbourhood plan policies] should be concise, precise and supported by appropriate evidence”. The evidence put forward to explain and justify the proposed important views at View K and View P is not robust, and as such these proposed designations do not have regard to national policy and would not meet Basic Condition (a).

Policy NH/2 of the adopted South Cambridgeshire Local Plan seeks to protect landscape character and the landscape of the National Character Areas. Policy HQ1 identifies the design principles for development, which includes preserve and enhancing the character of the area and responding to the site context in the wider landscape (criteria a) and providing high quality landscape (criteria m). Policy E/2 identifies the policy requirements for the extension to Cambridge Biomedical Campus, some of which are related to protecting landscape character – the full text of Policy E/2 is provided in Appendix A. Criteria 2(a) of Policy E/2 would retain and enhance the landscape boundary at the allocation, criteria (b) would provide a landscape setting for Nine Wells Local Nature Reserve, and criteria (g) relates to building heights for the allocation. It is anticipated that similar landscaping requirements would be identified for the preferred allocation for an additional extension to Cambridge Biomedical Campus in Policy S/CBC in the emerging Greater Cambridge Local Plan. Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. The landscape character around the villages, and at View K and View P, is already protected by Policy NH/2, and high quality landscaping is required for all developments by Policy HQ1 and specifically for the extension to Cambridge Biomedical Campus by Policy E/2. It is not necessary to duplicate development plan policies related to protecting landscape character, and to do so would be inconsistent with Paragraph 16(f) of the NPPF and would not meet Basic Condition (a).

It is suggested that the Neighbourhood Plan Group for draft S&GSNP review the Examiner’s Report for the Fulbourn Neighbourhood Plan (published April 2022), which also considered proposed locally important views for that document - see Paragraphs 7.33 to 7.35. In summary, the draft Fulbourn Neighbourhood Plan identified multiple viewpoints into and out of the village that should be protected. The Examiner concluded that those proposed viewpoints were general in nature, the importance of those views to the surrounding landscape was not explained, and the relationship between the views and the settlement was not identified. The Examiner recommended that all of the proposed locally important viewpoints be deleted. It is suggested that the outcome would be the same for the proposed important views identified in Policy S&GS12, including View K and View P.

It is noted that no other made neighbourhood plans in South Cambridgeshire include a policy to protect identified views. A consistent approach should be applied for all neighbourhood plans within the same district.

Summary Representation
It is considered that proposed View K and View P are general views of the countryside only, do not contain any particularly notable landscape or topographic features, and the assessment of those views does not explain why those views are important to warrant special protection. The evidence and assessment that has informed the decision to identify View K and View P is not robust. There are other adopted development plan policies that would ensure the delivery of appropriate landscaping with development. It is not necessary to duplicate other landscape development plan policies. It is requested that View K and View P are deleted.

Requested Change
It is requested that the proposed important views at View K (DNA Path next to bridge over railway) and View P (High point on Granhams Road) are deleted from Policy S&GS 13 and from Map 7, and that references to these views are removed from Appendix 7.


Policy S&GS 21: Delivering Stapleford and Great Shelford’s Improved Landscape Area

OBJECT

Policy S&GS 21 of draft S&GSNP seeks to designate all of the land on the eastern edge of Stapleford and Great Shelford as an Improved Landscape Area, for the purpose of countryside enhancement measures. The proposed Improved Landscape Area is shown on Map 14. Bullet No.8 in Paragraph 11.32 (and in the table following Paragraph 12.11) identifies a proposed area of open space adjacent to Nine Wells Local Nature Reserve (and adjacent to allocation Policy E/2). In summary, the proposed Improved Landscape Area incorrectly includes land allocated for an extension to Cambridge Biomedical Campus in the adopted South Cambridgeshire Local Plan, it refers to a new area of open space for use by Biomedical Campus employees when the allocation specifically excludes pedestrian access to adjacent areas, and it duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP.

Map 14 in draft S&GSNP identifies the extent of the proposed Improved Landscape Area and is referenced in Policy S&GS 21. Policy E/2 in the adopted South Cambridgeshire Local Plan allocates land for an extension to Cambridge Biomedical Campus. Map 14 incorrectly includes land allocated under Policy E/2 within the proposed Improved Landscape Area. The full text of Policy E/2 is provided in Appendix A of these representations, and the associated Proposals Map (Inset E South of Addenbrookes) is provided in Appendix B. Policy E/2 is identified as a strategic policy as set out in Appendix E of the adopted Local Plan. Therefore Map 14 and Policy S&GS 21 are not in general conformity with the strategic policy Policy E/2 in the adopted Local Plan, and as such do not meet Basic Condition (e). It is requested that, as a minimum, the land allocated by Policy E/2 in the adopted Local Plan is deleted from the proposed Improved Landscape Area shown on Map 14, so that Policy S&GS 21 does not apply to this land.

Bullet No.8 in Paragraph 11.32, which provides the supporting text to Policy S&GS 21, identifies a proposed area of open space adjacent to Nine Wells Local Nature Reserve for use by Biomedical Campus employees amongst others. This proposed area of open space is also referenced in the table after Paragraph 12.11. The proposed area of open space is located adjacent to allocation Policy E/2 in the adopted Local Plan. It is anticipated in Paragraphs 11.32 and 12.11 and in Policy S&GS 21 that the proposed area of open space would in part be delivered by development at Cambridge Biomedical Campus. However, criteria (e) of Policy E/2 specifically excludes pedestrian accesses from being provided on the western, southern and eastern boundaries of the allocated site, in order to minimise visitor pressure on Nine Wells Local Nature Reserve. Criteria (h) of Policy E/2 expects the proposed extension to Cambridge Biomedical Campus to include open space within the allocated site, and not elsewhere off-site. The table after Paragraph 12.11 indicates that development at Cambridge Biomedical Campus would in part be responsible for the delivery of the proposed area of open space shown on Map 14, but there is no evidence that this has been discussed or agreed with the Biomedical Campus or with the landowner Cambridgeshire County Council. Therefore, the proposed area of open space show on Map 14 and referenced in Paragraphs 11.32 and 12.11 and in Policy S&GS 21 are not in general conformity with the strategic Policy E/2 in the adopted Local Plan, and as such do not meet Basic Condition (e). It is requested that the reference to the proposed area of open space being required for Cambridge Biomedical Campus employees is deleted from Bullet No.8 in Paragraph 11.32, and that the reference to development at Cambridge Biomedical Campus being required in part to support the delivery of this open space is deleted from the table after Paragraph 12.11.

Policy CSF/5 of the adopted Cambridge Southern Fringe AAP, which is part of the adopted development plan for South Cambridgeshire, already designates the same land as the proposed Improved Landscape Area for a countryside enhancement strategy. The land designated by Policy CSF/5 is shown on Inset E of the adopted AAP. Policy CSF/5 provides additional detail of the landscape, planting and access measures required. The countryside enhancement strategy proposed in the adopted AAP are linked to and funded by development. There are no development allocations in draft S&GSNP that would support the delivery of the proposed Improved Landscape Area in Policy S&GS 20. It is considered that without an effective delivery mechanism the proposed Improved Landscape Area designation would not be implemented. Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. It is clear that the proposed Improved Landscape Area designation in Policy S&GS 20 duplicates Policy CSF/5 of the adopted Cambridge Southern Fringe AAP, which is not necessary. Policy S&GS 21 would be contrary to national policy, and as such would not meet Basic Condition (a). It is requested that the proposed Improved Landscape Area in Policy S&GS 21 and shown on Map 14 is deleted.

It should be noted that a green infrastructure initiative is proposed through the emerging Greater Cambridge Local Plan at Gog Magog Hills and Chalkland Fringe (see Policy BG/GI: Green Infrastructure), which is expected to carry forward the countryside enhancements strategy contained in the Cambridge Southern Fringe AAP.

Summary Representation
The proposed Improved Landscape Area incorrectly includes land allocated for an extension to Cambridge Biomedical Campus in Policy E/2 of the adopted South Cambridgeshire Local Plan. The supporting text to Policy S&GS 21 refers to a new area of open space for use by Biomedical Campus employees, when the Policy E/2 allocation specifically excludes pedestrian access to adjacent areas. The proposed Improved Landscape Area duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP. It is requested that the proposed Improved Landscape Area in Policy S&GS 21 and shown on Map 14 is deleted.

Requested Change
It is requested that, as a minimum, the land allocated by Policy E/2 in the adopted Local Plan is deleted from the proposed Improved Landscape Area shown on Map 14, so that Policy S&GS 21 does not apply to this land.

It is requested that the reference to the proposed area of open space being required for Cambridge Biomedical Campus employees is deleted from Bullet No.8 in Paragraph 11.32, and that the reference to development at Cambridge Biomedical Campus being required in part to support the delivery of this open space is deleted from the table after Paragraph 12.11.

It is requested that the proposed Improved Landscape Area in Policy S&GS 21 and shown on Map 14 is deleted.

INTRODUCTION
We have been instructed by Ely Diocesan Board of Finance (EDBF) to respond to the Reg.16 consultation for the draft Stapleford and Great Shelford Neighbourhood Plan (draft S&GSNP).

EDBF owns the land occupied by allotments to the west of Haverhill Road in Stapleford, which would be directly affected by some of the proposed policy designations within draft S&GSNP. A site location plan for the allotment land is provided in Appendix A. EDBF also owns land east of Haverhill Road in Stapleford. It is proposed to improve the path on the eastern side of Haverhill Road adjacent to EDBF land, and to create a new public rights of way route into the countryside on land that EDBF own.

In summary, EDBF objects to the following designations in draft S&GSNP:
• the proposed Visually Important Open Land designation at Stapleford Allotments (as shown on Map 8 and described in Appendix 6) on the basis that this term is not defined, this land is already designated as Green Belt which is specifically about retaining openness, and the site is surrounded by dwellings and trees so it is not visible from the wider surrounding area; and
• the proposed Local Green Spaces designation at Stapleford Allotments (LGS 8) (as shown on Map 11) on the basis that the land is already designated as Green Belt and it is not necessary to duplicate policy designations that have an identical status.

In due course draft S&GSNP will be examined by an Independent Examiner who will determine whether the basic conditions for a neighbourhood plan have been met. As explained in this response, it is considered that some of the policies and designations in draft S&GSNP do not meet Basic Condition (a) and are inconsistent with national policy.

At the end of the representations to each policy is a summary and the requested changes.

All references to the NPPF in these representations relate to the December 2023 version unless otherwise stated because of the transitional arrangements for neighbourhood plans contained in Paragraph 239 of the December 2024 NPPF.

REPRESENTATIONS TO DRAFT S&GSNP

Objectives

COMMENT
Paragraph 5.2 identifies 10 theme-based objectives for draft S&GSNP. These objectives are appropriate. It is noted that the objectives related to housing, biodiversity, community amenities and infrastructure, and countryside enhancement all refer to development, and it is assumed that additional development is necessary to support the delivery of those objectives. However, draft S&GSNP does not allocate any land for development and does not provide any policy support for development to be brought forward in the future through the emerging Greater Cambridge Local Plan process.

Draft S&GSNP should include a policy that supports the allocation of land for development at the villages through the emerging Greater Cambridge Local Plan process to deliver the housing, biodiversity, community amenities and infrastructure, and countryside enhancement related objectives.

Summary Representation
It is unlikely that those objectives that are associated with the delivery of additional development - housing, biodiversity, community amenities and infrastructure, and countryside enhancement - would be achieved without specific policy support for development.

Requested Change
No changes are requested to the objectives.


Policy S&GS 12: Protecting Stapleford and Great Shelford’s Landscape Character

OBJECT

Policy S&GS 12 relates to landscape character, and as part of this policy seeks to designate land as Visually Important Open Land. The land at Stapleford Allotments is designated as proposed Visually Important Open Land (part of Site Ref. 8), which is shown on Map 6 and described in Appendix 6. EDBF own the land at Stapleford Allotments. The allotments are unrelated to the adjacent land included within Site Ref. 8, and have a different character and relationship with that land and the surrounding area.

In summary, it is not necessary for land at Stapleford Allotments to be designated as Visually Important Open Land, when this land is already protected as Green Belt which is specifically about retaining openness, the landscape character of the existing allotments would be protected by adopted Local Plan policies, and the allotment land has limited visibility from the surrounding area.

Policy S/4 of the adopted South Cambridgeshire Local Plan seeks to maintain a Green Belt around Cambridge, with any development proposals in the Green Belt assessed against national policies contained in the NPPF. The Green Belt at Great Shelford and Stapleford is defined on the Local Plan Proposals Map Inset No.45. Stapleford Allotments fall within the land designated as Green Belt, and are located outside of the development framework for the villages. As highlighted in Paragraph 142 of the NPPF, openness is identified as an essential characteristic of the Green Belt. Policy NH/2 of the adopted South Cambridgeshire Local Plan seeks to protect and enhance landscape character, and refers to National Character Areas. Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”.

The proposed Visually Important Open Land designation at Stapleford Allotments would duplicate the openness requirement of the Green Belt designation that already applies to this land, and landscape character is already protected by Policy NH/2 of the adopted Local Plan. It is not necessary to duplicate development plan policies and national policies, and to do so would be inconsistent with Paragraph 16(f) of the NPPF. It is considered that, in respect of the proposed Visually Important Open Land designation at Stapleford Allotments, Policy S&GS 12 is not consistent with national policy, and as such would not meet Basic Condition (a).

Policy SC/8 of the adopted South Cambridgeshire Local Plan already protects existing allotments, including Stapleford Allotments. It is not necessary to duplicate development plan policies that already protect allotment use, and to do so would be inconsistent with Paragraph 16(f) of the NPPF.

There is no reference to the current Green Belt designation or the policy protection for existing allotments in the decision to identify Stapleford Allotments as Visually Important Open Land in Policy S&GS 12. If there had been then the land at Stapleford Allotments would not have been included within this proposed designation.

Appendix 6 of draft S&GSNP seeks to explain why land at Stapleford Allotments is proposed as Visually Important Open Land. The term ‘Visually Important Open Land’ is not defined in draft S&GSNP, but it appears from criteria (d) of Policy S&GS12 to be related to landscape matters. There is limited visibility of Stapleford Allotments from the surrounding area. There is housing located to the west, south and east of the allotments, and there are trees, hedgerows and other vegetation at all of the boundaries to the allotments. It is incorrect to describe the land at Stapleford Allotments as ‘visually important’, when in fact the land is fairly well enclosed. The allotments are adjacent to roads, residential uses, and a primary school, and as such are unlikely to be a particularly tranquil area that warrant special protection for this reason. Paragraph 041 (Ref ID: 41) of the Planning Practice Guidance states that “It [neighbourhood plan policies] should be concise, precise and supported by appropriate evidence”. The evidence put forward to explain and justify the proposed Visually Important Open Land designation at Stapleford Allotments is not robust, and as such this proposed designation does not have regard to national policy and would not meet Basic Condition (a).

Summary Representation
It is not necessary for land at Stapleford Allotments to be designated as Visually Important Open Land. This land is already protected as Green Belt which is specifically about retaining openness, the landscape character of the existing allotments would be protected by adopted Local Plan policies, and the allotment land has limited visibility from the surrounding area. It is requested that the proposed Visually Important Open Land designation of land at Stapleford Allotments (part of Site Ref. 8) is deleted.

Requested Change
It is requested that the proposed Visually Important Open Land designation of land at Stapleford Allotments (part of Site Ref. 8) is deleted from Map 6, and references to this proposed designation of the allotment land are removed from Appendix 6.


Policy S&GS 15: Local Green Spaces and Protected Village Amenity Area

OBJECT

Policy S&GS 15 seeks to designate land as Local Green Space. The land at Stapleford Allotments is designated as Local Green Space (Ref. LGS 7), which is shown on Map 9 and described in Paragraph 8.28. EDBF own the land at Stapleford Allotments.

In summary, it is not necessary for land at Stapleford Allotments to be designated as Local Green Space when they are already protected by Green Belt, and to do so would duplicate policies that already apply to the land and would be inconsistent with national policy.

Policy S/4 of the adopted South Cambridgeshire Local Plan seeks to maintain a Green Belt around Cambridge, with any development proposals in the Green Belt assessed against national policies contained in the NPPF. The Green Belt at Great Shelford and Stapleford is defined on the Local Plan Proposals Map Inset No.45. Stapleford Allotments fall within the land designated as Green Belt. It is noted that the emerging Greater Cambridge Local Plan does not seek to change the Green Belt status of the land at Stapleford Allotments. Section 13 of the NPPF sets out national Green Belt policy, including the purposes, when boundaries can be amended, the exceptional circumstances required to amend boundaries, and the types of development that are not inappropriate. The adopted Local Plan and the NPPF already provide strong protection from development for land located within the Green Belt, including the land at Stapleford Allotments. In addition, Policy SC/8 of the adopted Local Plan also seeks to protect existing allotments and to prevent their loss to other uses.

Paragraphs 105 to 107 of the NPPF explain the approach to designating land as Local Green Space. It is clear from Paragraph 107 that the development policies that would apply to land designated as Local Green Space should be identical to those that apply to land within the Green Belt. It is not necessary for land at Stapleford Allotments to be designated as both Local Green Space and Green Belt if the policies that apply to that land would be identical under both designations.
Paragraph 010 of Section Id.37 of the Planning Practice Guidance deals with circumstances where land protected by Green Belt should also be designated at Local Green Space. There is no assessment in draft S&GSNP as to whether any additional local benefit would be gains by designating Stapleford Allotments as Local Green Space when it is already designated as Green Belt. Stapleford and Great Shelford are not washed over by the Green Belt so the exception of identifying Local Green Space in villages included in the Green Belt does not apply in this case.

Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. It is considered that designating Stapleford Allotments as Local Green Space in Policy S&GS 14 would duplicate the Green Belt designation and policies contained in the adopted South Cambridgeshire Local Plan and the policies in the NPPF that already apply to this land. It is not necessary for Policy S&GS 14 to duplicate adopted Local Plan policies or national policy, and to do so would be inconsistent with Paragraph 16(f) of the NPPF. It is considered that Policy S&GS 14 is inconsistent with national policy, and as such would not meet Basic Condition (a).

The Examiner’s Report for the Waterbeach Neighbourhood Plan (published August 2021), which considered proposed Local Green Space designations, addressed this same matter - see Paragraphs 6.107 to 6.116 and Recommendation 20 of the Examiner’s Report. In summary, the Examiner concluded that it was not necessary for allotments located in the Green Belt to also be designated as Local Green Space because they were already adequately protected by the Green Belt designation. The Examiner recommended that the proposed Local Green Space designation of allotments was deleted from the Waterbeach Neighbourhood Plan. It is suggested that the outcome should be the same, and the proposed designation of land at Stapleford Allotments as Local Green Space should be deleted from draft S&GSNP.

Summary Representation
It is not necessary for land at Stapleford Allotments to be designated as Local Green Space. The allotments are already protected by Green Belt, and to do so would duplicate policies that already apply to the land and would be inconsistent with national policy. It is requested that the proposed Local Green Space designation at Stapleford Allotments (Ref. LGS 7) is deleted.

Requested Change
It is requested that the proposed Local Green Space designation at Stapleford Allotments (Ref. LGS 7) is deleted from Policy S&GS 15 and from Map 9, and references to this proposed designation are removed from Paragraph 8.28.



Policy S&GS 20: Protecting and Improving Routes into our Countryside

COMMENT

Policy S&GS 20 of draft S&GSNP seeks to protect and improve the public right of way network in order to provide routes into the countryside. Map 13 identifies those locations where there are aspirations for improving routes into the countryside. The approach towards improving the public right of way network and access to the countryside would be consistent with Paragraph 104 of the NPPF.

There are a number of ways that new routes and connections to the public right of way network can be created. It might be possible to agree a right of access with a landowner, but this is unlikely if there would be no benefit to the landowner. A public body might allow access across its land as part of providing a benefit to the local community, but this would depend on landownership arrangements. It is more likely that new public rights of way would be agreed and delivered if there were benefits to a landowner, such as in conjunction with development. However, draft S&GSNP does not provide any policy support for development that might deliver new public right of way routes and connections.

Paragraph 11.15 of draft S&GSNP refers to a community aspiration to improve the existing path alongside Haverhill Road, between Stapleford and the A1307, in order to provide access for all non-motorised users e.g. pedestrians, cyclists, horses. EDBF own part of the land adjacent to the existing path. It is not clear from Paragraph 11.15 whether the proposed improvements to the path could be undertaken entirely within public highway owned land, the width of the land required for the proposed path and associated infrastructure, and what landscaping/boundary treatments would be provided adjacent to the proposed path. There has been no discussion or agreement with EDBF about improving this path.

If land owned by EDBF is required to improve the existing path alongside Haverhill Road, it is requested that this should be discussed with them in advance.

Summary Representation
The approach towards improving the public right of way network and access to the countryside would be consistent with national policy. Paragraph 11.15 of draft S&GSNP refers to a community aspiration to improve the existing path alongside Haverhill Road, between Stapleford and the A1307, in order to provide access for all non-motorised users If land owned by EDBF is required to improve the existing path then this should be discussed with them in advance.

Requested Change
No changes are requested to Policy S&GS 20.

Please find attached the East West Railway Company Limited (EWR Co) response to the submission version of the Stapleford and Great Shelford Neighbourhood Plan. For the avoidance of doubt, Adams Hendry Consulting Ltd are the planning agent for EWR Co.

Please see attached the Council’s formal response to the Stapleford & Great Shelford Neighbourhood Plan Regulation 16 consultation.

Please find our response to this consultation attached.

Please find Natural England’s response in relation to the above mentioned consultation attached.

Please find attached the formal Representation to the Stapleford and Great Shelford Neighbourhood Plan Consultation (Regulation 16) from Nightingale Land and The Hill Group.