Gamlingay Neighbourhood Plan Submission version

Support

Representation ID: 56537

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

Objective 1 Housing Growth

Objective 1 recognises the need for appropriate housing growth in Gamlingay including the need for smaller and adaptable homes. This is supported.

Object

Representation ID: 56538

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

OBJECTIVE 4: COMMUNITY AMENITIES AND FACILITIES

The supporting text to Objective 4 advises that Policy GAM7 designates the former First School Playing Field as new Local Green Space with pedestrian access. It also advises that Policy GAM8 supports development of the former First School buildings for educational and community uses and safeguards the site for 10 years. Cambridgeshire County Council objects to Policies GAM7 and GAM8 under basic conditions A, D and E,
see representations submitted in respect of Policies GAM7 and GAM8 below. Thus, Cambridgeshire County Council also objects to the supporting text to Objective 4 under the same basic conditions.

Support

Representation ID: 56539

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

PARAGRAPHS 4.12 and 4.13

Paragraph 4.12 advises that the Bedfordshire Rural Communities Charity (BRCC) Housing Needs Survey Report (2018) indicates a particular demand for smaller 1-2-bedroom homes and bungalows in Gamlingay to meet the needs of single people requiring accommodation on their own, as well as older people seeking to downsize. Paragraph 4.13 recommends developers focus on less expensive, smaller, and adaptable 2 to 3- bedroom houses and bungalows. Cambridgeshire County Council supports the provision of smaller homes which could be explored as part of a mixed-use scheme at the former First School site.

Object

Representation ID: 56540

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

PARAGRAPH 4.60

Paragraph 4.60 advises that there is a shortfall of places for care of children during their early years in Gamlingay. It goes on to state that the existing former First School buildings would provide an ideal location for pre-school care. Policy GAM8 is proposing the reuse of the buildings on the former First School site for educational and community purposes where a need (e.g. for pre-school provision, a new doctors’ surgery or relocation of the Coop) can be met. Cambridgeshire County Council objects to Paragraph 4.60 under basic conditions A, D and E (see representations submitted in respect of Policy GAM8). Cambridgeshire County Council acknowledges its duty to provide pre-school places. However, while a detailed feasibility study of the site has not yet been carried out, based on experience in the area it is considered likely that a sole pre-school use would not be viable. Also, due to the size of the buildings multiple site occupants would be required. To produce an effective whole site solution, it is highly likely that a mixed use scheme will be required to support such facilities, however, this should not be restricted to education and community uses. Rather, greater flexibility should be provided to ensure a suitable viable scheme can be developed. This view was expressed by Cambridgeshire County Council as part of the Regulation 14 Consultation.

Support

Representation ID: 56541

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

PARAGRAPH 4.62
COMMENT
The former First School field is private land with no public access. Access to the former First School field is only granted through private agreements with Cambridgeshire County Council.

Object

Representation ID: 56542

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

GAM6 – COMMUNITY AMENITIES AND FACILITIES

Policy GAM6 states that the loss of amenities and facilities will be resisted unless it can be demonstrated that efforts have been made to secure their continued use and alternatives are provided. Cambridgeshire County Council objects to Policy GAM6 under basic
Condition A as the policy is not considered clear and unambiguous as required under Paragraph 16(d) of the NPPF and Paragraph 041 (Ref. 41-041-20140306) of the NPPG.
The policy does not define what falls within “amenities and facilities” for the purpose of the policy, or what an applicant is expected to demonstrate to show that “efforts have been made to secure their continued use”. Furthermore, it has not taken into account the
existing level of provision within the settlement. In line with the Local Plan, it is suggested that the wording be updated to “village services and facilities, including village pubs,shops, post offices, banks and building societies, community buildings and meeting
places, sports venues, cultural buildings, places of worship or health facilities, where such loss would cause an unacceptable reduction in the level of community or service provision in the locality”. This change in wording is also required to meet basic condition E (see below).

Policy GAM6 also does not meet basic condition E which requires general conformity with the strategic policies contained in the development plan. This includes Local Plan Policy SC/3: Protection of Village Services and Facilities which seeks to protect village services and facilities. However, as set out above, Policy GAM6 does not include the same definition of facilities and services as Policy SC/3. Furthermore, Policy SC/3 sets out clear guidance on what will be considered in determining the significance of the loss of a village service or facility:

a) “The established use of the premises and its existing and potential contribution to the social amenity of the local population;
b) The presence of other village services and facilities which provide an alternative, with convenient access by good local public transport services, or by cycling or
walking; and how these remaining uses will cope with displaced users; and any unacceptable impact of those alternative services or facilities;
c) The future economic viability of the use including the results of marketing of the premises for a minimum of 12 months at a realistic price and in appropriate cases
financial information.”
Neighbourhood Plan Policy GAM6 does not provide this clarity which is considered important for the application of the policy. Policy GAM6, therefore, does not conform with
Policy SC/3 of the Local Plan.

Object

Representation ID: 56543

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

GAM7 – DESIGNATION OF THE FORMER FIRST SCHOOL FIELD, GREEN END AS A LOCAL GREEN SPACE (TL 23582 52417) AND NEIGHBOURHOOD PLAN MAPS

Policy GAM7
Policy GAM7 designates the former First School Field as Local Green Space with pedestrian access. Cambridgeshire County Council objects to Policy GAM7 under basic Condition A as the policy is not realistic or deliverable. Paragraph 16(b) of the NPPF states that plans should “be prepared positively, in a way that is aspirational but deliverable”. This is repeated in Paragraph 005 (Ref. 41-005-20190509) of the NPPG which specifically covers neighbourhood plans. Paragraph 002 (Ref. 10-002-20190509) of the NPPG also
states that “it is the responsibility of plan makers in collaboration with the local community, developers and other stakeholders, to create realistic, deliverable policies”.

The former First School Field is private land with no public access (including no public rights of way across the land). Access is only granted through private agreements with Cambridgeshire County Council. Cambridgeshire County Council, as landowner, clearly
stated within their Regulation 14 consultation response that “access to the play fields will be granted, on permission only basis, to documented authorised users”. A Local Green Space designation does not confer any rights of public access over what exists at present
(NPPG, Paragraph 017, Ref. 37-017-20140306).
Therefore, there is no public access and the inclusion of “with pedestrian access” is neither realistic nor deliverable. Consequently, Policy GAM7 is not appropriate and does not meet basic Condition A.

Cambridgeshire County Council also object to the boundary of the proposed Local Green Space designation which includes the Scouts Hut and car park. Having regard to national policies and advice contained in guidance, the inclusion of the Scouts Hut and car parking within the proposed Local Green Space designation is considered inappropriate and does not meet basic Condition A.

The purpose of Local Green Space designations is to provide special protection for green areas of particular importance to local communities (NPPF, Paragraph 101; NPPG, Paragraph 005, Ref. 37-005-20140306). It is not considered that the Scouts Hut or associated car park fall within the definition of “green areas” to which Local Green Spaces designations apply.
While the definition of green areas includes “land where sports pavilions, boating lakes or structures such as war memorials are located, allotments, or urban spaces that provide a tranquil oasis” NPPG, (Paragraph 013, Ref. 37-013-20140306), the Scouts Hut and car park comprise built development that does not read as part of the former First School Field green area. Rather, the Scouts Hut and car park form part of the built-up area including the
former school. Therefore, they are considered to fall beyond the definition of a green area. Assets such as the Scouts Hut are covered under different areas of protection including through the existing Asset of Community Value (ACV) listing.

Neighbourhood Plan Maps
The following maps show the boundary to the proposed Local Green Space designation which includes the Scouts Hut and car park. This includes:
 Map 4: Landscape Setting
 Map 7: Key Policy Areas 1-12
 Map 9: Community Amenities and Facilities
 Map 10: Walking Cycling and Horse-Riding Routes
 Map 11: Gamlingay Wood – GAM12
As set out above, having regard to national policies and advice contained in guidance, the inclusion of the Scouts Hun and car parking within the proposed Local Green Space designation is considered inappropriate and does not meet basic Condition A.

Object

Representation ID: 56544

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

GAM8 – REUSE OF THE FORMER FIRST SCHOOL BUILDINGS, GREEN END (TL
23647 52413)

Policy GAM8 proposes the reuse of the former First School buildings and new buildings for educational and community uses (e.g Use Classes a, b, e, f, g). Cambridgeshire County Council objects to Policy GAM8 under basic conditions A, D and E.

Object

Representation ID: 56545

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

Policy GAM10 requires new residential and business units to contribute towards the provision and maintenance of new paths for the purpose of cycling, walking and horse riding between the village, hamlets, employment sites and neighbouring villages. It sets
out the level of contribution required. Appendix 3 sets out further information on developer contributions.

Cambridgeshire County Council objects to Policy GAM10 as it is not considered to meet basic Condition A. Paragraph 005 (Reference ID: 41-005-20190509) and Paragraph 001 (Reference ID: 10-001-20190509) of the NPPG advise respectively that: “Neighbourhood plans may also contain policies on the contributions expected from development, but these and any other requirements placed on development should accord with relevant strategic policies and not undermine the deliverability of the neighbourhood plan, local plan or spatial development strategy.”

“Plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure). These policy requirements should be informed by evidence of infrastructure and affordable housing need, and a proportionate assessment of viability that takes into account all relevant policies, and local and national
standards, including the cost implications of the Community Infrastructure Levy (CIL) and
section 106…”

Insufficient evidence has been provided on how the proposed contributions relate to the strategic policies within the Local Plan or how they will impact the deliverability of the neighbourhood plan, local plan, or spatial development strategy. Furthermore, a
proportionate assessment of viability has not been provided. The lack of evidence also conflicts with Paragraph 31 of the NPPF and Paragraph 041 (Ref. 41-041-20140306) of the NPPG.

The policy is also ambiguous as the term “business developments” has not been defined so it is not clear what it is intended to include. Paragraph 16(d) of the NPPF and Paragraph 041 (Ref. 41-041-20140306) of the NPPG require policies be clear and unambiguous, so that it is obvious how the decision maker should apply them.
It should be noted that the former First School Playing Field was not identified as recreation space within the Council’s Recreation and Open Space Study (July 2013) nor within the Services and Facilities Study (March 2014).

Object

Representation ID: 56546

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

GAM11 – LANDSCAPE AND NATURAL ENVIRONMENT

Policy GAM11 advises that green spaces within developments should be consolidated to create a network of publicly accessible formal and informal green spaces – green infrastructures – for sport and recreation. Cambridgeshire County Council objects to Policy
GAM11 on the grounds that it is not deliverable (as required under Paragraph 16(b) of the NPPF) as not all green space within developments will necessarily be publicly accessible. Therefore, in its current wording the policy does not meet basic condition A.

It is suggested that the words “public open” be inserted at the start of the sentence so that it reads:
“Public open green space within developments should be consolidated to create a network of publicly accessible formal and informal green spaces – green infrastructures – for sport and recreation.”