Fulbourn Neighbourhood Plan - submission version

Comment

Representation ID: 59338

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Fulbourn Conservation Area Appraisal

In parallel with the pre-submission public consultation of the Plan SCDC was carrying out a consultation on the revised Fulbourn and Fulbourn Hospital Conservation area appraisal (CAA). This appraisal was adopted in September 2021 and we consider needs to be mentioned within the Plan. Amendments to the conservation area were made in this new appraisal – it would be helpful if the new boundary were shown within the Plan or mention that they have changed from those shown in Figure 2.

6. The CAA includes a list of possible non-designated heritage assets as well as a map showing buildings that make a valuable contribution to the overall character of the Fulbourn conservation area. The buildings identified as non-designated heritage assets have been included in Policy FUL/05 Protecting and Enhancing Village Character but are not listed or shown on a map. We consider this a missed opportunity. A map is included in the CAA which could be added to the Plan. The policy is relying upon the future user of the Plan cross referring to the CAA.

Comment

Representation ID: 59339

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Extant planning permissions
Within the Fulbourn Neighbourhood Area there are some large schemes where outline planning permission has been given by SCDC and reserved matters are still to be considered. We wish to ensure that the policies contained within the neighbourhood plan take into account /are complementary to these permissions and do not adversely attempt to over-ride them. For example, that for the Fulbourn and Ida Darwin Hospital sites which are identified for redevelopment in the adopted Local Plan – Policy H/3. We will specify within the comments below for each policy where we consider it appropriate that changes should be made.

Relevant list of planning applications contained in full submission

Comment

Representation ID: 59340

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

3 Planning Policy Framework

Figure 2. The policy designations from the Local Plan used in this map do not use the correct terms. e.g., Village Amenity Area should be Protected Village Amenity Area. We would suggest that such corrections should be made to the Plan post examination and ahead of the referendum to avoid confusion with the different designations

Comment

Representation ID: 59341

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

4 Local Context

Paragraph 4.44 - There’s a very minor typo – include ‘which has a ditch with an important vascular and nationally scarce plant.’ It would be helpful to also include the common name ‘Fen pondweed’ for clarity.

Comment

Representation ID: 59342

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/01 Protecting the Distinctiveness and Landscape Setting of Fulbourn.

The supporting text to Policy FUL/1 has undergone much change since the Regulation 14 consultation. It more clearly describes the intensions of the policy setting out clearly the difference between the different elements in the policy for protecting the setting of Fulbourn – the important visual gap, important countryside frontages and the locally important views. This is to be welcomed.

Part 2 of policy –There should be a reference to the map that the Important Visual Gap is identified on ‘….as shown on Map 9 and the Policies Map’. We welcome that Figure 9 is consistent with the current Ida Darwin application.

Part 4 of policy –Part 5 of the policy explains the role of these views and we consider this wording should sit within the same section of the policy as the list of views. It should be noted that planning policy cannot control agricultural land uses or retain woodland unless it includes protected trees or is an ancient woodland.

Comment

Representation ID: 59343

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/02 – Development Outside the Development Framework.

Part 1 – This is repeating the Local Plan policy for development frameworks and does not, in our view, offer anything specific to Fulbourn. (Policy S/7 Development Frameworks).

Part 2b – We consider that this criterion should have a caveat regarding tree surveys and allowing for essential works to improve woodlands/trees and removal of dangerous trees.

Part 2c - The policy mentions ‘appropriate levels of street lighting’ but does not explain in the supporting text what would be appropriate. How would a planning officer know what is appropriate in determining a planning application?

Should there be a definition of what is meant by dark skies? Nowhere around Cambridge is a designated dark sky zone so should a different term, such as minimising light pollution arising from new development, be used to improve the darkness of certain areas? There may also need to be a consideration of the balance between lighting and safety.

Part 2d – How would this criterion be achieved to maintain in perpetuity a soft outer edge to Fulbourn?

Comment

Representation ID: 59344

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

7 Enhancing Rural Environment

Paragraph 7.8 – This paragraph could be updated to reflect that the Environment Act has Royal Assent. Wording such as the following could be added to the Plan – ‘The Environment Act 2021 has introduced a requirement for all developments in England to deliver ‘biodiversity net gain’ of at least 10%. There will be a transition period of two years to enable Natural England to establish the delivery mechanisms.’

Comment

Representation ID: 59345

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/03 Creating a Connected Green Infrastructure Network.
The supporting text has been changed a lot from the version of the Plan consulted upon at Regulation 14. A new policy has been added. SCDC has concerns that this policy has not been subject to full consultation prior to submission and could be considered a major change to the Plan. Development proposals are being asked to contribute towards the creation of an extended Green Infrastructure Network. In the previous Plan this was a simple criterion in Policy FUL/04 Protection and Enhancement of Nature Features - 2b.

The policy is supported by Figure 11 which shows an indicative green infrastructure network. Whilst supporting the principle of showing clearly the green infrastructure within the parish, we have concerns that this is the first time such a map has shown the extent of this infrastructure in the Draft Neighbourhood Plan. The supporting text to this policy sets out a clear narrative as to why such an infrastructure would be important including relevant studies that promote such greening, but this is new information to the plan.

The inclusion of a connected green infrastructure network is welcomed. With support and advice from the Wildlife Trust for Beds, Cambs and Northants, this network has the potential to contribute to the Nature Recovery Network to be developed in Cambridgeshire in line with the requirements of the Environment Act 2021.

Comment

Representation ID: 59346

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/03 Creating a Connected Green Infrastructure Network.

Part 1 of the policy – It is not clear how development proposals could contribute towards the creation of an extended Green Infrastructure network. Since much of the network is outside of the built-up area of the village over agricultural land within the Green Belt what development in the future on this land would be expected to contribute to the creation of the network? Planning practice guidance notes that planning obligations should only be uses where it is:
• necessary to make the development acceptable in planning terms;
• directly related to the development; and
• fairly and reasonably related in scale and kind to the development.

These tests are set out as statutory tests in regulation 122 (as amended by the 2011 and 2019 Regulations) and as policy tests in the National Planning Policy Framework. It is not clear how the intent of the Policy could be achieved by applying these tests.

Part 1 – final sentence – We are unsure what is meant by the term ‘potentially’ comprise – this implies uncertainty of what is included in the green infrastructure.

Part 1a – e – It is unclear whether all these features are included in Figure 11. We consider that these features should be clearly identified as they are included within the policy. Within (a) where are all the existing accessible open space? What is meant by designated green space – the local green space and Protected Village Amenity Areas? Which wildlife sites – ones designated? In (b) what is natural greenspace? In (c) where are the new green spaces and habitats – are these shown in Figure 11? In (d) are the permissive countryside routes shown? In (e) such areas of open space could be extensive.

This section could emphasis linking and improving connectivity, for example between locally protected sites, such as County Wildlife Sites, and nationally protected sites, such as SSSIs’. The terms ‘designated green spaces’ and ‘wildlife sites’ are rather vague. Where are the green spaces designated and are the wildlife sites designated anywhere?

Part 2 of the policy – The areas shown on Figure 11 indicating the network covers much land around the parish. It extends over both the Fulbourn and Ida Darwin hospital sites- this policy must take account of the existing planning permissions on these sites. Any future development within the parish would be impacted by this policy which strengthens our concerns about the specific lack of consultation on its detail.

Part 3 – How would this be achieved? Would creating such legal agreements make for a viable policy? Who would take responsibility for managing and maintaining the network on private land – SCDC? Parish Council? Wildlife Trust? The policy is unclear. It would be better to state that Green Infrastructure provided as part of a development will be retained through conditions.

Comment

Representation ID: 59347

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Figure 11
There a number of features shown on this map where it is not clear what they represent. What are ‘Possible new habitats/natural greenspace (Wildlife Trust)’? Are these explained within the Plan? Is the intension that they are protected/created within Policy FUL/03? Where are the sources for the ‘Existing Habitats and Woodlands’? Many of the areas shown are outside of the designated neighbourhood area. Whilst recognising that a green network does not stop at the border of a parish a neighbourhood plan cannot have a policy that extends beyond its neighbourhood area.

We are concerned that the ‘indicative green infrastructure network seems not to have a clear boundary on the map but rather has a symbol that fades in and out of focus. We will need clear boundaries to add into a policies map, so it is clear what areas are within the influence of the policy. Does the use of the term ‘indicative’ imply the network does not have a clear geographical layout?

It is unclear from the map what routes are for ecological movements versus those for sustainable transport like walking or cycle routes.