Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

STRATEGY

Representation ID: 59023

Received: 13/12/2021

Respondent: A P Burlton Turkey’s Ltd

Agent: Iceni Projects

Representation Summary:

The council should consider refining the vision to ensure that it does not ignore or underplay the potential of rural areas and the need for sustainable development in rural areas to meet local needs and support the vitality and viability of rural communities.

Full text:

Support is expressed for the Council’s Vision to “create thriving neighbourhoods with the variety of jobs and homes we need; increase nature, wildlife and green spaces; and safeguard our unique heritage and landscapes” (page 20-21).

However, as it currently stands, the proposed vision is centric to the sustainability of the City of Cambridge and the transport patterns involved with commuting. Simultaneously, there is insufficient regard for Greater Cambridgeshire’s rural settlements, with settlements such as Meldreth that by virtue of their infrastructure connectivity and scope for sustainable travel, offer the opportunity to deliver much needed sustainable development.

To ensure that the Vision to “create thriving neighbourhoods with the variety of jobs and homes [that Cambridgeshire] needs” is fully achieved, it is crucial that rural areas receive a suitable amount of development to meet local housing need and enable the benefits of development to reinvigorate and regenerate communities.

Paragraph 79 of the National Planning Policy Framework (NPPF) supports a suitable level of development should being delivered at rural settlements, by stating that “housing should be located where it will enhance or maintain the vitality of rural communities”.

With regards to the Council’s aims, support is also expressed towards the provision of ‘Great Places which sustain the unique character of South Cambridgeshire’ and ‘Homes which meet the needs of the diverse community’. The stated aims should be applicable to every settlement class (as listed in the settlement hierarchy), and therefore to fully achieve these aims, it is important that the Council ensure that the needs of rural communities are not overlooked and that suitable development opportunity sites are positively planned for and not predicated from being brought forward through negative, restrictive and unwieldly policies.

The council should consider refining the vision to ensure that it does not ignore or underplay the potential of rural areas and the need for sustainable development in rural areas to meet local needs and support the vitality and viability of rural communities.

Distributing a suitable amount of housing to rural areas of Cambridgeshire would help the council meet its housing requirements in a balanced way. It would also avoid an overreliance on housing allocations at Cambridge.

This is supported by paragraph 62 of the NPPF which seeks to ensure that the size, type and tenure of housing required by different groups in the community is reflected in planning policy, including in particular for affordable housing, families with children and older people. In addition, paragraph 78 of the NPPF states that in the delivery of rural housing, “planning policies and decisions should be responsive to local circumstances and support housing developments that reflect local needs.”

Comment

Greater Cambridge Local Plan Preferred Options

How much development and where?

Representation ID: 59056

Received: 13/12/2021

Respondent: A P Burlton Turkey’s Ltd

Agent: Iceni Projects

Representation Summary:

It is proposed that the council should allocate a larger amount of housing to rural areas through the redevelopment of windfall sites, which should include farm buildings that are contiguous to settlements. Such opportunities, which should be logical and positively enabled through the Plan, are needlessly curtailed through the existing approach. Additionally, the present restrictions on development size at rural settlements should be reviewed and increased.

Full text:

The Council has proposed to provide the vast majority of its new housing through strategic urban extensions to the City of Cambridge and new settlements. Whilst this approach has its merits, the approach would contribute towards a notable loss of Green Belt land and undeveloped greenfield land. The Green Belt is fundamental to UK planning and is in place to ensure that urban sprawl from major settlements is contained, and to encourage brownfield development (para 138, NPPF).

Development on Green Belt land should be viewed unfavourably by the Council and should only exceptionally be pursued after the authority has fully examined all other reasonable options for meeting its identified need for development (Paragraph 141 of the NPPF).

The above factors identify that there is a clear need for the Council to consider a wider range of options that can help meet a full range of housing needs. It is proposed that the council should allocate a larger amount of housing to rural areas through the redevelopment of windfall sites, which should include farm buildings that are contiguous to settlements. Such opportunities, which should be logical and positively enabled through the Plan, are needlessly curtailed through the existing approach.

On the one hand, the draft Local Plan recognises the value of windfall sites to help contribute housing need. However, under the current proposals, the Plan approach is failing to identify and optimise some windfall sites and the housing yield that can be achieved through them, due to the combination of excluding farm buildings/sites from settlement boundaries and applying low development thresholds to rural settlements, some of which like Meldreth, are highly sustainable and suitable locations for development. The Plan should therefore include Farm Buildings/sites that lie within or are contiguous with settlements to help ensure that the delivery of rural housing can be achieved through Windfall sites, whilst the present restrictions on development size at rural settlements should be reviewed and increased. Windfall sites should be maximised by the council, as they can help improve the sustainability and quality of rural environments, whilst reducing the loss of Green Belt and undeveloped greenfield land. Furthermore, developments can be focussed where suitable infrastructure exists, to ensure that these vital assets are not underplayed and ensure that the Council's Vision and Aims to create sustainable transport patterns can be comfortably achieved.

Comment

Greater Cambridge Local Plan Preferred Options

S/JH: New jobs and homes

Representation ID: 59068

Received: 13/12/2021

Respondent: A P Burlton Turkey’s Ltd

Agent: Iceni Projects

Representation Summary:

It is urged that the council may take a more flexible approach towards the allocation and delivery of housing sites in Rural Areas. The Council has a duty to ensure that Green Belt land is protected, and not developed on unless there are no other suitable options available. The proposed approach is ignoring and indeed preventing obvious development opportunity sites such as farm buildings within/contiguous with settlements from being developed. Such sites would enable investment and regeneration in rural communities, whilst minimising the amount of greenfield land needed for housing.

Full text:

Policy S/JH of the draft Local Plan identifies the proposed housing need for the plan period of 2020-2041. A housing requirement of 44,400 is stated, and equates to 2,111 dwellings per annum which is significantly above the minimum housing need established by the standard method (para 61 of the NPPF). The Council’s decision to create a higher housing target than what is required by the standard method is supported, provided that housing provisions can accommodate for a diversity of needs in Greater Cambridgeshire and are in accordance with national planning guidance.

It is urged that the council may take a more flexible approach towards the allocation and delivery of housing sites in Rural Areas. The Council has a duty to ensure that Green Belt land is protected, and not developed on unless there are no other suitable options available. The proposed approach is ignoring and indeed preventing obvious development opportunity sites such as farm buildings within/contiguous with settlements from being developed. Such sites would enable investment and regeneration in rural communities, whilst minimising the amount of greenfield land needed for housing.

The Council is required to provide a supply of housing for the next five years to ensure that it can meet its housing delivery targets. The Housing Delivery Study sets out the development trajectory for each site and the expected time frame for its completion. The council state that there is a housing supply of 5.15 years which is close to the minimum amount required. The uncertainty around the deliverability of sites means that there is reasonable potential for the council to not meet its housing targets if multiple developers fail to provide housing within the five year period. Therefore, it is proposed that the council should consider additional suitable housing sites through a more dispersed approach to development across settlements within the Plan area that could be delivered within the five year period to ensure that it can safely meet its housing target.

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 59080

Received: 13/12/2021

Respondent: A P Burlton Turkey’s Ltd

Agent: Iceni Projects

Representation Summary:

Land at Bury End Farm, Meldreth (HELAA site 40284)

It is requested that the development strategy increases its provision of housing for rural areas where redundant farm buildings exist, contiguous with a settlement and where suitable infrastructure exists to support sustainable living and working patterns.

Full text:

The proposed Development Framework sets out a strategy for the pattern, scale and design quality of the homes and economic land provided in Greater Cambridge. To ensure that the distinctive character of towns and villages is protected, the council place emphasis on approving developments which are well-integrated with existing settlements (Policy S/DS, page 29-30 of the draft Local Plan).

The council have proposed to concentrate development in the City of Cambridge to accommodate for its growing number of jobs (as set out in Policy S/JH). Housing provisions for rural areas beyond the Green Belt (as outlined in Policy S/DS) are mainly in large rural towns. As a result, the plan does not provide development opportunities at numerous settlements within the Plan area, despite settlements like Meldreth, which offers an obvious development opportunity through the redevelopment of the Bury Farm site within/contiguous with the settlement, and has the potential to achieve highly sustainable patterns of development due to its infrastructure and connectivity to employment areas. The proposed Development Strategy cannot therefore be supported in its current form, as it does not promote sustainable development in highly sustainable locations at rural settlements beyond the green belt.

Areas where there is significant infrastructure to sustain rural communities and simultaneously a lack of new housing, such as Meldreth, represent an ideal opportunity for the new Plan to positively promote development opportunities on sites containing existing buildings at locations contiguous with existing settlements. It is therefore requested that the development strategy increases its provision of housing for rural areas where redundant farm buildings exist, contiguous with a settlement and where suitable infrastructure exists to support sustainable living and working patterns.

Comment

Greater Cambridge Local Plan Preferred Options

S/SH: Settlement hierarchy

Representation ID: 59095

Received: 13/12/2021

Respondent: A P Burlton Turkey’s Ltd

Agent: Iceni Projects

Representation Summary:

It is recommended that the proposed limit of housing for settlements identified in the hierarchy should be reviewed with a view to increasing the development threshold, and should not be a mandatory requirement but instead serve as a guide, with the relative sustainability of the site/settlement providing a basis for increasing the development threshold of a site. Such an approach would place sustainability at the heart of decision taking and ensure that development opportunities are not needlessly inhibited by a negatively conceived blanket policy approach.

Full text:

Objection is raised to the Settlement Hierarchy approach set out in the South Cambridgeshire Local Plan. The restriction on housing numbers for smaller settlements, such as group villages which limits development to 8 to 15 homes, reduces the scope for the recycling of underutilised sites and buildings and predicates the amount of development that could be achieved through windfall development. As a result, not being able to utilise such sites will lead to the needless release of undeveloped greenfield land, some of which is Green Belt.

It is therefore recommended that the proposed limit of housing for settlements identified in the hierarchy should be reviewed with a view to increasing the development threshold, and should not be a mandatory requirement but instead serve as a guide, with the relative sustainability of the site/settlement providing a basis for increasing the development threshold of a site. Such an approach would place sustainability at the heart of decision taking and ensure that development opportunities are not needlessly inhibited by a negatively conceived blanket policy approach.

Meldreth is an example of a settlement which will suffer as a result of the Settlement Hierarchy approach advocated. It is classed as a group village, which means that the draft Local Plan imposes a maximum scheme size of 8 dwellings, or 15 dwellings if the site represents the best use of a brownfield site. However, the settlement contains farm buildings such as Bury Farm that are within/contiguous with the settlement and boasts excellent public transport infrastructure and connectivity to major employment. In this regard, the settlement has exceptional access bus services and railway services, which provides access to Cambridge in 17 minutes, or London St Pancras in approx. 60 minutes. Additionally, a large existing commercial site neighbours the settlement which means sustainable living and travel patterns can be enhanced with commensurate housing to align with the jobs and infrastructure that already exist.

Comment

Greater Cambridge Local Plan Preferred Options

S/SB: Settlement boundaries

Representation ID: 59112

Received: 13/12/2021

Respondent: A P Burlton Turkey’s Ltd

Agent: Iceni Projects

Representation Summary:

Land at Bury Farm, Abington Road, Litlington (HELAA site 40208)

If settlement boundaries are to be defined, the Plan approach should be adapted to include obvious development opportunities, such as large-scale farm buildings contiguous with existing settlements within the settlement boundaries.

Full text:

Objection is raised in respect of the proposed approach to settlement boundaries (and rural settlements more widely). In this regard, the policy approach of including the present extent of the built up area, and deliberately excluding farm buildings even if they are contiguous with or within the settlement, stifles opportunities to deliver much needed growth at rural settlements, many of which within the Plan area would positively benefit from new development through opportunities to deliver affordable housing for local people, as well as much needed growth and investment into communities. If settlement boundaries are to be defined, the Plan approach should be adapted to include obvious development opportunities, such as large-scale farm buildings contiguous with existing settlements within the settlement boundaries. These buildings are frequently unsightly, overly dominant in scale and give rise to amenity complaints, making them bad neighbour uses. Their redevelopment can deliver significant planning benefits, yet they are needlessly hindered by an unjustified approach to settlement boundaries that precludes them from being brought forward.

Bury Farm in Meldreth is a relevant case example, where a large scale farm complex within/adjoining the settlement of Meldreth, with bus and rail services adjoining, is needlessly excluded from coming forward as a windfall site, despite the potential to deliver a highly sustainable development, comparable with or superior to most development sites in the Plan area.

The policy approach of precluding farm buildings/sites beyond settlement boundaries from being developed is irrational. There are very few allocations at rural settlements in the draft Plan, there are very few windfall sites within such settlements and the Plan can ill afford to ignore and hinder such an obvious and suitable source of supply.

Comment

Greater Cambridge Local Plan Preferred Options

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

Representation ID: 59123

Received: 13/12/2021

Respondent: A P Burlton Turkey’s Ltd

Agent: Iceni Projects

Representation Summary:

It is unclear why so little development is distributed to rural settlements beyond the Green Belt. There are settlements such as Meldreth that offer scope to deliver highly sustainable development due to its infrastructure connectivity and imbalance of jobs to homes, that have been completely overlooked. Sites such as Bury Farm that constitute a bad neighbour use, that are sustainably located and offer the potential to create highly sustainable patterns of development should be positively supported through positive land use allocations.

Full text:

It is unclear why so little development is distributed to rural settlements beyond the Green Belt. There are settlements such as Meldreth that offer scope to deliver highly sustainable development due to its infrastructure connectivity and imbalance of jobs to homes, that have been completely overlooked. Sites such as Bury Farm that constitute a bad neighbour use, that are sustainably located and offer the potential to create highly sustainable patterns of development should be positively supported through positive land use allocations.

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