Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 58488

Received: 13/12/2021

Respondent: BDW Homes Cambridgeshire & The Landowners (Mr Currington, Mr Todd, Ms Douglas, Ms Jarvis, Mr Badcock & Ms Hartwell)

Agent: Optimis Consulting Ltd

Representation Summary:

Land West of Beach Rd, Cottenham (new site 59409)

Existing centres represent sustainable locations for residential development. It is important that future housing growth be distributed throughout the district in order to safeguard the future vitality and viability of existing settlements. The need for growth to sustain and help existing settlements thrive should be promoted.

A Green Belt Review should be undertaken and where to identify locations where the removal of sites from this designation will be appropriate in time. These sites should then be safeguarded for future development either in case there is an issue with delivery of strategic allocations or to inform future iterations of the plan.

Full text:

We support the proposed development strategy for Greater Cambridge in seeking to “direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way.”

We do not agree however that this should dictate that the plan promote few strategic sites at the expense of all other existing centres in the District. The development strategy as proposed is overly reliant on strategic allocations. It does not consider what may happen to 5-year housing supply if these limited locations encounter delivery issues. Equally it does not consider the impact of both limiting growth in existing settlements such as Cottenham and promoting it elsewhere.

Very few sites for housing are identified outside of the strategic allocations. No sites are identified to contribute to Cottenham’s future vitality and viability. It is evident that existing planning permissions in Cottenham will be built out over the next few years. The Plan then envisages no further development in Cottenham through to 2041.

This is not a proactive strategy for maintaining and enhancing the vitality of a sustainable
location. The Plan must set out options for the longer term future of sustainable locations such as Cottenham
Delivering extensions to existing communities and continuing to build on the strong cultural and social aspects of the larger settlements is vital in the progress towards achieving healthier communities. Proposing modern homes that create improved sustainable credentials and add vitality to existing neighbourhoods is not only a requirement of local and regional policy, but one that is adopted within the National Planning Policy Framework.

Limiting growth to just a few strategic allocations presents risks with disproportionate settlement growth presenting a real threat to settlements such as Cottenham resulting in stagnated growth and poor support for local facilities. Furthermore the over reliance on strategy allocations is high risk in terms of continual supply and draw down for 5 year land supply. It is suggested that at the very least Green Belt is reviewed and where sites may be suitable for removal from this designation this should be identified and acknowledged and such sites should safeguarded for future residential development should it be required.

As per the proposals presented in the Vision Document submitted alongside these representations it is proposed that Land off Beach Road, Cottenham is identified in the Greater Cambridge Local Plan for the development of up to 80 houses.

It is considered that the development of the site could contribute substantially to the social and economic growth of Cottenham Its significance as an important settlement within the district. Extensive assessments of the site have concluded that its development would result in minor impacts to the character and openness of the Green Belt and the wider landscape, whilst also outlining the opportunity to provide policy compliant levels of biodiversity
enhancement and affordable housing.

It is clear that development of this site will not impinge on the environs of Cambridge. A Green Belt review has been undertaken having regard the potential development of the site concluding that the release of the parcel for residential development would have no impact on 4 of the 5 functions of Green Belt and only minor impacts on the purposes of the Cambridge Green Belt as identified in the Greater Cambridge Local Plan.

Similarly, given the nature of the site and the surrounding landscape, a Landscape Visual Impact Assessment has also been prepared for the site. It notes that the site is within a transitional area at the edge of the Fen Edge Village and bordered by a series of orchards, hedges and trees to the southeast, by (mostly modern 2-storey brick) housing on Brenda Gautry Way to the north and further residential areas to the west. To its northeast and eastern
edge, the site fronts Beach Road and includes a number of dwellings on the road frontage, with further estate development beyond. It is considered that development of the site can be managed sensitively so as to be read as part of the existing settlement and minimise any impacts on the local landscape.

The vision document demonstrates that the site can accommodate new rural housing in an environmentally sensitive, sustainable and responsible manor. It is proposed that development of the site can deliver approximately 80 new homes offering opportunities across a range of house types, sizes and tenures including an appropriate proportion of affordable housing and green open space. The proposals as outlined through the Vision Document would deliver new high quality homes and open space in a sustainable and deliverable location, with access to essential local services and facilities, employment, public transport, education and leisure.

To conclude, Cottenham’s sustainable location within the district, in combination with the highly accessible transport connections, make the village an appropriate location for future growth. The site itself represents a wholly viable option for residential development and it is recommended therefore, that this site be allocated for residential development in the emerging Greater Cambridge Local Plan.

Comment

Greater Cambridge Local Plan Preferred Options

S/SH: Settlement hierarchy

Representation ID: 58491

Received: 13/12/2021

Respondent: BDW Homes Cambridgeshire & The Landowners (Mr Currington, Mr Todd, Ms Douglas, Ms Jarvis, Mr Badcock & Ms Hartwell)

Agent: Optimis Consulting Ltd

Representation Summary:

Cottenham’s role in the Spatial Strategy be reconsidered. Cottenham be identified as a Rural Centre allowing for the consideration of any future residential proposals on their respective merits having regard to the accepted sustainability of the village.

Full text:

The Plan states that ‘Cottenham should be classified as a Minor Rural Centre reflecting a revision to the criteria for a segregated public transport route such as the Greater Cambridge Partnership schemes of the Cambridgeshire Guided Busway, which is not the case of Cottenham.’

We strongly disagree that Cottenham should be relegated in the settlement hierarchy.

Policy S/SH fails to define each categorisation of settlement simply stating the limits that will
be placed on development within each tier.

In the South Cambridgeshire Local Plan Rural Centres are defined as those that are the largest, most sustainable villages of the district. They have good access to a secondary school (either within the village or accessible by good public transport), employment opportunities, a variety of services and facilities and have good public transport services to Cambridge or a market town.

Meanwhile minor Rural Centres are defined as those that have a lower level of services, facilities and employment than Rural Centres, but a greater level than most other villages in South Cambridgeshire, and often perform a role in terms of providing services and facilities for a small rural hinterland.

We maintain on this basis that Cottenham should remain a Rural Centre. The shortcomings in the approach proposed in the Greater Cambridge Plan is summarised below:

Cottenham continues to benefit from good public access and a range of shops and services. It remains a sustainable location for future development. By all other measures Cottenham remains comparable to the other Rural Centres, if anything the recent developments in the village have consolidated this. It is considered that this site remains suitable for in excess of 30 houses. To summarise:

Cottenham continues to offer good access to a secondary school, employment opportunities, a variety of services and facilities and have good public transport services to Cambridge.

In terms of population, amenities and services Cottenham remains largely comparable to the other Rural Centres. Equally it is evident that Cottenham has a greater range of facilities relative to the minor rural centres and is better able to accommodate growth;

The Greater Cambridge Plan (First proposals) does not define what is deemed to constitute a Town, Rural Centre or Minor Rural Centre. Notwithstanding, if you look at population, amenities and services however Cottenham remains largely comparable to Histon & Impington, Great Shelford & Stapleford and Sawston. Equally it is evident that Cottenham has a greater range of facilities relative to the minor rural centres;

It is stated within the Greater Cambridge First proposals that the reason for changes to the settlement hierarchy, is due to a revision to the criteria for a Rural Centre, in that they must have high quality public transport in the form of a segregated public transport route, such as the Greater Cambridge Partnership schemes, or the Cambridgeshire Guided Busway. There is no justification for this fixation on certain forms or mediums of public transport. There is no doubting that Cottenham is accessible to the Greater Cambridge Area. There appears no sound logic for demoting the centre on this basis.

Cottenham benefits from a bus service to Cambridge every half hour. This service takes approximately 31 minutes where as services from Great Shelford and Stapleford take approximately 20-32 minutes, current services from Cambourne take approximately 30-50 minutes and services from Sawston take approximately 45 minutes. There is no clear basis on which Cottenham is therefore now deemed less accessible than the other Rural Centres therefore;

The Neighbourhood Plan (May 2021) identifies a desire locally / need to consolidate and enhance existing services and amenities, with policy that acknowledges the potential for sites in excess of 50 houses to come forward. Key issues highlighted in the plan include limitations on education, medical, leisure and recreational facilities. Aspirations in the plan point to the retention of Cottenham as a Rural Centre. Demotion of Cottenham’s status runs contrary to the policy aspirations of the Neighbourhood Plan.

The viability of Cottenham remains dependent on a critical mass of residents. It is in this context that the new residential development has been permitted in recent years. The neighbourhood plan identifies 500 units are to be added to Cottenham following permission granted in 2017-2018. This will increase the population further in
Cottenham. It is counter intuitive to down grade Cottenham in the settlement hierarchy having just allowed this growth which in effect consolidates its status as a rural centre.

Further to the above, demotion of Cottenham’s status at the expense of the nearby centres of Waterbeach and Northstowe presents real challenge to the future viability of Cottenham, in terms of services and amenities, given there potential appeal. The Neighbourhood Plan raises concern about the potential of rival centres to draw residents from Cottenham. Again, the promotion of local centres at the expense of Cottenham, which is instead being actively downgraded, fly’s in the face of the neighbourhood plan aspirations.

In determining applications for previous housing development in Cottenham, South Cambridgeshire District Council and the Planning Inspectorate have concluded that Cottenham is a sustainable, suitable location for large scale housing development.

Cottenham was promoted from a Minor Rural Centre to a Rural Centre in the South Cambridgeshire Local Plan 2018 on the basis of its accessibility generally and its range of facilities and services. Since this time further residential development has taken place in the village. In this context it is unclear why Cottenham is considered to have become less sustainable.

A blanket limit of 30 units on any development site in a centre such as Cottenham, that is able to offer a sustainable range of services and facilities, runs contrary to the NPPF. Cottenham has in recent years been viewed as a sustainable location for additional housing. It is clear on this basis that any policy should allow for the review of the respective merits of any future residential proposals rather than simply prohibiting development on the basis of a generic, uninformed benchmark. Similarly it is clear that this policy runs contrary to Policy COH/2-2 of the Cottenham Neighbourhood Plan.

Attachments:

Comment

Greater Cambridge Local Plan Preferred Options

S/SB: Settlement boundaries

Representation ID: 58497

Received: 13/12/2021

Respondent: BDW Homes Cambridgeshire & The Landowners (Mr Currington, Mr Todd, Ms Douglas, Ms Jarvis, Mr Badcock & Ms Hartwell)

Agent: Optimis Consulting Ltd

Representation Summary:

Land West of Beach Rd, Cottenham (new site 59409)

Policy should not put a banket ban on development outside of the settlement boundary, in effect pre-judging any such proposal, rather it should set out a series of criteria allowing development proposals to be assessed on its respective merits.

Full text:

We acknowledge a requirement to identify existing settlements and their boundaries. It should be acknowledged however that this reflects a snapshot in time. A blanket ban on development outside of a settlement boundary should not be adopted as is in effect currently proposed. Rather policy should allow for the consideration of all future proposals on their respective merits in line with the NPPF.

Land off Beach Road, Cottenham is closer to many existing facilities and services than existing built-up areas of the settlement. As has been determined on previous applications approved in Cottenham the location of a site outside the settlement boundary does not necessarily prejudice its accessibility nor the ability for development to integrate with and complement existing development.

Attachments:

Comment

Greater Cambridge Local Plan Preferred Options

BG/BG: Biodiversity and geodiversity

Representation ID: 58500

Received: 13/12/2021

Respondent: BDW Homes Cambridgeshire & The Landowners (Mr Currington, Mr Todd, Ms Douglas, Ms Jarvis, Mr Badcock & Ms Hartwell)

Agent: Optimis Consulting Ltd

Representation Summary:

It is strongly recommended that the policy is amended to require a 10% net gain in bio-diversity, as per the approach established through the Environment Act.

Full text:

We acknowledge the importance of delivering bio-diversity net gain as an integral part of future development. Notwithstanding this, no sound basis has been provided for the requirement for a 20% net gain in biodiversity proposed under this policy.

The Government considers a 10% net gain sufficient to mitigate the impact of new development and it should be recognised that the Environment Act does not set this as a minimum. No basis is presented therefore as to why Greater Cambridge should adopt a different approach to the other areas of the Country.

The result of requiring a 20% net gain will likely be to make some schemes unviable. Equally it will potentially reduce the number of units coming forward on sites requiring identification and delivery of further sites for development which is counter intuitive to the original objective.

Comment

Greater Cambridge Local Plan Preferred Options

GP/LC: Protection and enhancement of landscape character

Representation ID: 58508

Received: 13/12/2021

Respondent: BDW Homes Cambridgeshire & The Landowners (Mr Currington, Mr Todd, Ms Douglas, Ms Jarvis, Mr Badcock & Ms Hartwell)

Agent: Optimis Consulting Ltd

Representation Summary:

Policy should continue to allow for the consideration of development on its own merits, alongside any potential impacts recognising that development can bring benefits in the context of landscape character.

Full text:

We acknowledge the need to fully consider the effects of development and change in the landscape character. Policy should not seek to pre-judge development proposals however and instead ensure it allows for the consideration of a proposal on its respective merits. Equally it is important that policy should not focus solely on impacts and equally recognise benefits development can bring. To this end we support acknowledgement that new development can provide opportunities to enhance the landscape, such as by improving the edge of settlements.

Policy should continue to allow for the consideration of development on its own merits, alongside any potential impacts recognising that development can bring benefits in the context of landscape character.

Comment

Greater Cambridge Local Plan Preferred Options

GP/GB: Protection and enhancement of the Cambridge green belt

Representation ID: 58510

Received: 13/12/2021

Respondent: BDW Homes Cambridgeshire & The Landowners (Mr Currington, Mr Todd, Ms Douglas, Ms Jarvis, Mr Badcock & Ms Hartwell)

Agent: Optimis Consulting Ltd

Representation Summary:

Land West of Beach Rd, Cottenham (HELAA site 59409)

Policy should allow for the removal of sites from the Green Belt for residential development where it can be show that this would not prejudice the purposes of Cambridge’s Green Belt.

Full text:

Policy makes it clear that the purpose of Green Belt identified around Cambridge is to:
• Preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre;
• Maintain and enhance the quality of its setting;
• Prevent communities in the environs of Cambridge from merging into one another and with the city.

A Green Belt Review of Land off Beach Road has been undertaken. Having specific regard to the above purposes of the Cambridge Green Belt it is considered that this parcel of land only partial contributes to maintaining and enhancing the quality of its setting. On this basis it is concluded therefore that there would only be limited effect therefore from releasing the land from Green Belt for development.

Comment

Greater Cambridge Local Plan Preferred Options

GP/QD: Achieving high quality development

Representation ID: 58514

Received: 13/12/2021

Respondent: BDW Homes Cambridgeshire & The Landowners (Mr Currington, Mr Todd, Ms Douglas, Ms Jarvis, Mr Badcock & Ms Hartwell)

Agent: Optimis Consulting Ltd

Representation Summary:

Where these objectives can be demonstrated policy should make clear that this will carry significant weight in the consideration of the proposal.

Full text:

Policy GP/OP seeks to achieve high quality development. It requires that development be designed with communities in mind, namely to:
• Ensure that buildings are orientated to provide natural surveillance and maximise opportunities to create active ground floor uses;
• Create active edges on to public space by locating appropriate uses, as well as entrances and windows of habitable rooms next to the street;
• Use design to minimise adverse impact on neighbouring buildings and spaces in terms of privacy and overlooking, sunlight and daylight, overshadowing and other microclimate considerations, artificial lighting, vibration, noise, fumes and odour, and other forms of pollution;
• Introduce mixed uses proposals in a way that can benefit all occupants where appropriate, avoiding the mixing of incompatible uses.

The promotion of good design is supported. The Masterplan proposals accompanying these representations demonstrate the potential to deliver these objectives through the development of Land of Beach Road.

Comment

Greater Cambridge Local Plan Preferred Options

STRATEGY

Representation ID: 58532

Received: 13/12/2021

Respondent: BDW Homes Cambridgeshire & The Landowners (Mr Currington, Mr Todd, Ms Douglas, Ms Jarvis, Mr Badcock & Ms Hartwell)

Agent: Optimis Consulting Ltd

Representation Summary:

The aims of the Greater Cambridge Local Plan are supported.

In terms of housing targets, Neighbourhood Plans should be afforded the ability to bring forward housing developments appropriate to their needs and objectives.

A refined strategy should be considered that allows an appropriate proportion of growth to take place in sustainable locations to compliment that being focused to strategic allocations.

Full text:

The representations to the Greater Cambridge Local Plan are attached in full, supported by a vision document for the site, 'Land west of Beach Road, Cottenham'.

We support the aims of the Greater Cambridge Local Plan, as set out at Section 2 of the Plan, to respond to:

• Climate Change;
• Bio-Diversity & Green Spaces;
• Wellbeing and Social Inclusion;
• Great Places;
• Jobs;
• Homes; and
• Infrastructure.

Recommendation: Support

Neighbourhood Plan Housing Targets (P27)

Neighbourhood planning is specifically aimed at ensuring communities retain direct power to develop a shared vision for their neighbourhood and shape the development and growth of their local area. It seems wholly inappropriate therefore for the Greater Cambridge Plan seeks to centralise these decisions stating that “…As such we are not relying on neighbourhood areas providing additional homes to meet our requirements.” Similarly, it is appropriate that emerging policies in the Greater Cambridge Local Plan reflect those made in Neighbourhood Plans.

Recommendation: Where an appropriate case can be made, in the context of national planning policy, Neighbourhood Plans should be afforded the ability to consider and bring forward housing developments appropriate to their needs and objectives.

What Alternatives did we Consider (P28)

It is not clear that alternative patterns of growth were considered in preparing the plan. The rationale for relegating Cottenham in the settlement hierarchy (see below) is unclear and to this end it is similarly not clear to what extent retention of Cottenham as a Major Rural Centre has been considered.

Recommendation: A refined strategy should be considered that allows an appropriate proportion of growth to take place in sustainable locations to compliment that being focused to strategic allocations.

Comment

Greater Cambridge Local Plan Preferred Options

S/RRA: Allocations in the rest of the rural area

Representation ID: 60724

Received: 13/12/2021

Respondent: BDW Homes Cambridgeshire & The Landowners (Mr Currington, Mr Todd, Ms Douglas, Ms Jarvis, Mr Badcock & Ms Hartwell)

Agent: Optimis Consulting Ltd

Representation Summary:

Land West of Beach Rd, Cottenham (HELAA site 59409)

Policy should allow for the removal of sites from the Green Belt for residential development where it can be show that this would not prejudice the purposes of Cambridge’s Green Belt.

Full text:

Policy makes it clear that the purpose of Green Belt identified around Cambridge is to:
• Preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre;
• Maintain and enhance the quality of its setting;
• Prevent communities in the environs of Cambridge from merging into one another and with the city.

A Green Belt Review of Land off Beach Road has been undertaken. Having specific regard to the above purposes of the Cambridge Green Belt it is considered that this parcel of land only partial contributes to maintaining and enhancing the quality of its setting. On this basis it is concluded therefore that there would only be limited effect therefore from releasing the land from Green Belt for development.

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