Draft Gamlingay Village Design Guide SPD

On behalf of Wyboston Lakes Ltd we object to the draft Gamlingay Village Design Guide in respect of the proposed Sensitive Village Edge zone 3 'Fields to the edge of the brook' designation. The grounds for objection are:
I. The Design Guide Introduction clarifies the purpose and scope of the Guide, and states 'the Gamlingay Village Design Guide has been prepared to amplify and build on the requirements set out within policy HQ/I: Design Principles in the adopted 2018 Local Plan, as well as supporting the other policies within the Local Plan which relate to the built and natural character, and distinctiveness of South Cambridgeshire'. Policy HQ/I: Design Principles clarifies 'All new development must be of high quality design, with a clear vision as to the positive contribution the development will make to its local and wider context.......' Both the Design Guide and Policy HQI are clearly about ensuring an appropriate quality of design that has regard to the setting of sites. Therefore, it is inappropriate for the Design Guide to introduce land designation principles, such as 'sensitive Village edges' and this goes beyond the scope of Policy HQI and the SPD.
2. Chapter 4 of the Gamlingay Village Design Guide in relation to Landscape Setting identifies the objector's land 'Fields to edge of the brook' as a sensitive village edge and the Guidance 4.3 states 'The area bounded by the brook...to the south west edge of the village has a sensitive and distinct landscape character which should be maintained'. However, there is no explanation:
* why this area is particularly sensitive?
* how it differs from the other edges of the village?
* how the sensitivity has been assessed?
* what was the methodology for the selection 'sensitive village edges' and by what criteria? Without this justification the identification of 'sensitive village edges' is unfounded.
3. The adopted Local Plan identifies Important Village Gaps (Policy NH/ 13) where land that enhances the setting, character and appearance of a village and retains a sense of connection between the village and its rural origins and surroundings should be kept open and free from development. This land is not a designated Important Village Gap and the proposal is introducing a designation which should be addressed and examined through the statutory Local Plan process.
4. The 'Note to the Reader' section of the Village Design Guide states that the SPD will be a material consideration in the determination of planning applications in Gamlingay and goes onto clarify 'that the SPD cannot make new planning policy', however, the proposed 'Sensitive Village Edge' designation for areas which should be maintained would create new planning policy, contrary to the purposes of the SPD. Moreover, this5.
6.
7. statement is more stringent than criterion a. of Policy HQI, which requires development proposals to
Preserve or enhance the character of the local urban and rural area and respond to its context in the wider landscape'.
The proposed 'Fields to the edge of the brook' sensitive village edge location is a paddock enclosed by established tree and hedge vegetation that abuts the village on the eastern side. The site is understood to have been used for clay extraction in the early 20th century and in the 1970s it was used for landfill with material from various building site. Due to the poor quality of the subsequent restoration the site is unsuitable for anything other than low grade grazing use. The area was the subject of a planning application refused in February 2018 (LPA Ref S/3170/17/OL) and in the officer report it was acknowledged by the case planning officer 'The application site occupies a discreet location screened by established hedging and trees that generally restrict public views into the site'. In relation to the proposed development the Council's expert Landscape Officer also advised 'There would be negligible effects on the wider and local landscape character areas' and 'The proposed development could be integrated into the local landscape without causing any significant detriment to the landscape character, visual and visual amenity'. These observations by professional officers undermine the significance of 'Fields to the edge of the brook' as a particularly sensitive village edge.
The proposed 'Fields to the edge of the brook' sensitive village edge location is not subject to any national designations and there are no public rights of way running through or immediately adjacent to the site boundaries. The site is within the Greensand Ridge Landscape Character Area which is a swath of land on the Bedfordshire border, described as 'This is a very small character area associated with the undulating dip slope of the Lower Greensand ridge. It is drained by small streams and there are some locally steep slopes. The fairly wooded landscape is interspersed with medium sized arable fields, small areas Of pasture and market gardening. There are also small areas or remnant parkland and heath. Despite the presence of some worked out gravel pits, the area retains a predominantly rural character'. This is not a particularly remarkable character area and the site does not exhibit any unique landscape qualities. The site is in a discreet location screened by established hedging and trees that generally restrict public views into the site. Therefore, given the assessment of the site its designation as a Sensitive Village Edge is not justified.
Guidance 4.1 states the aim to "preserve the separation of...Little Heath, by retaining the open landscape character between this and the village." However, the Village Character the map in Chapter 5 identifies the Little Heath character area directly abutting the existing village of Gamlingay. The Guidance and the plan are therefore contradictory and need reviewing.