Fulbourn Neighbourhood Plan - submission version

Comment

Representation ID: 59348

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Figure 12
The key to this map is similar to that of Figure 11 but it also includes ‘Other green spaces’. Are these protected in the Plan? It is unclear what these areas are.

Comment

Representation ID: 59350

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/04 Protection and Enhancement of Natural Features.
Part 2c – Mention could be made in the supporting text to this policy to highlight the Local Plan Policy SS/8 Sustainable Drainage Systems. Currently this criterion has no supporting text to explain why it is included in a policy.

Part 3 – We had previously asked for justification to be included in the supporting text as to why this section of the policy relates only to new developments of 10 units or more The NPPF defines a major housing site as being of ten or more or a site with an area greater than 0.5 hectares. We were concerned that the policy needed to be more flexible so that it takes into account if a developer submits a scheme for 9 dwellings and then a subsequent scheme for 8 which is equivalent to over 10 but not covered by your policy. We would suggest that the Policy would be clearer if the first line made reference to 0.5 hectares as well as 10 dwellings.

Part 3a – How does this link to the new policy FUL /03 that creates the Green Infrastructure? In the Regulation 14 version of the Plan this was the only element asking developers to contribute to a green infrastructure which had not been shown on a map. Habitat to promote a net gain in biodiversity is within FUL/03 1c – is this duplicating?

Part 3b – As with Part 3a of this policy it is unclear how this relates to the new policy FUL/03. Are the new areas of ‘Natural Greenspace’ those that are identified in Figures 11 and 12? Are these greenspaces formed as part of the development or is there an expectation for off-site contributions? There is no explanation in the supporting text as to what is meant by ‘Natural England’s definition of ‘Accessible Natural Greenspace’. On Figures 11and 12 these ‘new habitats’ are outside the built area of the village where development of any scale would not be expected to take place.

It is suggested that the supporting text makes reference to the document ‘Understanding the relevance and application of the Access to Natural Green Space Standard’ Natural England 2008. This updates information about the promotion and delivery of accessible nature green space. The English Nature report 153 is from the 1990s.

Part 3c – As noted in relation to our comments on Policy FUL/04, developers can only be asked to mitigate for losses outside their site (i.e. in the Parish) through a Section 106 Planning Obligation and where the Government rules can be met. They must be:
• 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.

It should be noted that it will be possible to deliver Biodiversity Net Gain offsite outside the parish boundary if it contributes to strategic ecological networks or the Nature Recovery Network (yet to be drafted as an outcome of the Environment Act). Guidance on this is currently being drafted.

Part 3d - How would this criterion be achieved? Who would be able to test that the drainage patterns would not be compromised? How would a developer demonstrate this? Suggest it should state that proposals should be supported by supporting evidence that demonstrates that the existing drainage patterns will not be compromised. The supporting text could set out the parameters for what should be submitted.

Part 4 - It is unclear who would be responsible for monitoring the legal agreements to achieve this part of the policy. These can only be associated with a planning consent and therefore the policy should state "appropriate legal agreements associated with a planning consent."

Support

Representation ID: 59351

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/05 Local Green Spaces and Protected Village Amenity Areas

We welcome that the wording has been amended to this policy since Regulation 14. We do not consider it is necessary to include the second sentences within part 1 and part 2 of the policy as this is repeating the relevant Local Plan policies.

Part 1 – In the first sentence delete the unnecessary ‘a’ after designated as.

We welcome the unique references for each LGS and PVAA and note that additional sites have been added to the policy some of which were suggestions by us in our response to the Regulation 14 consultation.

Comment

Representation ID: 59352

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/05 Local Green Spaces and Protected Village Amenity Areas

New LGSs have been added at Fulbourn Hospital Parkland and Fulbourn Hospital Old Cemetery - The parish council has recently notified the landowners of these proposed designations. We have concerns that the extent of these LGSs is more that the ‘important green space’ shown in the adopted Fulbourn and Fulbourn Hospital Conservation Appraisal 2021( See page 27) Also, the Fulbourn hospital site has a development brief that includes some sites for development within the areas proposed as LGS. We have concerns therefore at the proposed boundaries and how these might impact the development of these sites. https://scambs.moderngov.co.uk/documents/s73905/Development%20Brief.pdf

Comment

Representation ID: 59353

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/05 Local Green Spaces and Protected Village Amenity Areas

For planning officers dealing with planning applications, it could be confusing if similar criteria are used in different policies and not clearly stated once in one policy. For example, criteria c in this policy about trees and hedgerows is already referred to in part in 1d of Policy FUL/04. There is no need to repeat policy requirements in separate policies as the Plan will be read as a whole and as appropriate to an application.

Part 2a – This criterion cross refers to Policy FUL/07 but we are unsure why this is required as these issues are not specifically mentioned in this policy?

Parts 2c – This appears to be repeating the requirements in Part 1d +1e of Policy FUL/04 regarding trees?

Part 2d – This criterion previously had ‘diverse’ built frontages which has now been replaced by ‘fragmented’. We still have concerns about how such terms could be interpreted. Is it clear what the policy is asking for and it might be better if these areas of fragmented frontage were perhaps defined on a map?

Part 3 – We remain concerned about an unduly heavy emphasis on contemporary design in policies FUL06 and FUL/07. Neither ‘contemporary’, used in FUL/07, nor ‘creative and contemporary’ used in FUL/06, is defined in the Glossary, and it is not clear whether the term ‘contemporary’ means ‘in the modernist tradition’, or ‘in vogue at the time of the present neighbourhood plan’, or ‘eschewing emulation of previous architectural styles’, or something else. There are many places in the village, including within the conservation areas and the vicinity of listed buildings, where modernist buildings or extensions, or innovative development beyond that tradition might be very appropriate and enhance the historic environment, but there are other places where this approach would not be the most appropriate, and some designs styled ‘contemporary’ would be harmful to the setting of some of the listed buildings and the overall character of the area.

The wide variety of architectural styles in the village is acknowledged and we agree that Fulbourn’ s character will be preserved and enhanced by continuing variety of building styles, including innovative development and that in the modernist tradition. However, foregrounding ‘contemporary’ design as Policy FUL/06 does and requiring a ‘contemporary’ approach to be considered in extensions, as Policy FUL/07 does, is unduly prescriptive, and could lead to planning decisions which are harmful to the setting of listed buildings or the character of the conservation area. We question whether this level of prescription in design is consistent with local plan policy or national planning guidance.

It is suggested that part 3 of the policy should explicitly state that those instances when a contemporary response is not appropriate i.e., “…and where this would negatively impact on designated and non-designated heritage assets".

Part 4 of policy - A section has been added to this policy to include a reference to buildings identified as non-designated heritage assets (NDHA) in the Fulbourn CAA. These NDHAs have not been shown on a map or listed within the Plan which we consider is a missed opportunity to add weight to their protections and future enhancement. (See maps on pages 5-7 of the CAA and Chapter 9 with the NDHA listed on pages 36-37 of the CAA).

Support

Representation ID: 59354

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/07 Building and Landscape Design

This policy has been revised since the Regulation 14 consultation. It is welcomed that it more clearly laid out now for future users of the Plan.

Comment

Representation ID: 59355

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/07 Building and Landscape Design

Part 1 –The Village Design Guide is referred to in this section. Reference to any documents that supersede it would help maintain longevity of the policy, as is the case in other policies - i.e.: “Village Design Guide and any documents that supersede this”.

Part 2a Height - This section refers to buildings of 2.5 storeys and 2 storeys having a similar height. In most instances, this is not the case as there will be some height differential between a 2 storey and a 2.5 storey building.

Part 2b Density – Does this section simply repeat the Local Plan policy – Policy H/8: Housing Density? What is unique to Fulbourn other than mentioning other policies within the Plan? The wording about density allows for a flexible design-led approach for densities above 30 dph. It should be noted that existing outline consents at the Ida Darwin and land east of Teversham Road sites have some areas with housing densities above 30 dph.

Part 2c Built form - This could be made clear to recognise that the character of the village is made up of different materials, colours, and styles and the design response should relate to those materials, colours and styles found in Fulbourn. Perhaps the reference to different materials relates to them being used in a single building? This should be clarified.

There are two sections within this policy numbered 2. This will need amending.

Part 3a-d – Do the criteria in this section add anything locally specific for Fulbourn or is it simply repeating Policy HQ/1 Design Principles from the Local Plan and the Design Guide SPD?

Part 4d –We do not consider that this criterion adds anything to the policy and should be removed. All development must take account of relevant policies in the Development Plan.

Comment

Representation ID: 59356

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/08 – Village Street and Lane Layout

Part 2d – Planning policy does not have control of signage – this would be a highway matter.

Comment

Representation ID: 59357

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

10 Residential development

Paragraphs 10.2 -10.3 - The introduction to this chapter has been much rewritten. Mention is made of the emerging Greater Cambridge Local Plan and the options considered in the making of the local plan. Whilst this Plan must be aware of the emerging local plan, we do not consider it appropriate to include this within the supporting text as it is likely to need to be updated as the emerging local plan moves towards its next formal stage. Until the local plan is examined it is not certain what strategy will be included in it.

Paragraph 10.7 for clarity it should be stated that it was Cambridgeshire ACRE that carried out the survey not Cambridge.

The Ida Darwin and Teversham Road Sites – In the Regulation 14 version of the Plan there was a policy for these two sites. We commented that it was not necessary to repeat Local Plan policies H/3 and SS/3 and only additional criteria should be included in the Plan. The option has been taken to no longer retain a policy in the Plan but policy like language is used in paragraph 10.11 – 10.12 for these two sites. It should be noted that this wording has no weight in the determination of applications. The Village Design Guide does provide detailed design guidance relating to these sites which could have been included in a policy in the Plan to add weight.(See page 16)

Comment

Representation ID: 59359

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/09: Larger Residential Development (10 or more units)

Part 1a – This criterion requires an appropriate housing mix. There is no evidence in the supporting text to set out what may be appropriate in Fulbourn to meet local needs. It remains unclear why at least 5% in the housing mix should be built to be accessible and adaptable dwellings M4(2) standard. This has not been justified. There is no information in the supporting text other than mention that the local residents think the needs of an ageing population should be considered. As this is for housing schemes of 10 or more units in order to achieve 5% of anything the scheme would have to be much more than 10 – (a development of 50 units to get 2.5 homes). How is this different from Policy H/9 in the Local Plan except it is requiring at least 5% but without clear justification.

Part 1b – We consider that this criterion simply repeats the Local Plan policy on affordable home (Policy H/10).

Part 2a - There is no information in the supporting text about a Building for a Healthy Life (BHL) assessment and where a developer could find out how to carry such an assessment out. Any appraisal system should be agreed with the local planning authority as the decision-making body.

We consider that the use of BHL toolkit should be used with caution as it does not provide absolute results on design quality. It is useful as an engagement tool or for discussion to agree on what the development should aim to achieve. It uses a traffic light system for 12 questions with the aim to score greens, reduce ambers and avoid reds. As the tool is for all development it is very difficult to differentiate in the document different responses to village/rural areas as compared to urban and could conflict with the objectives of neighbourhood plan. A reference to the VDG SPD would be more appropriate.

Part 2b – Written Ministerial Statement HCWS488 by the Secretary of State for Communities and Local Government dated 25 March 2015 states that “neighbourhood plans should not set ……….. any additional local technical standards or requirements relating to the construction, internal layout or performance of new dwellings.” It is not clear what this adds to the policies in the Local Plan about renewable energy - Policy CC/3 Renewable and Low Carbon Energy in New Developments. We adopted a new SPD in 2020 which we had suggested could be cross referenced in the supporting text about renewables - Greater Cambridge Design and Construction Supplementary Planning Document

Part 3a. – This appears to be a new criterion included in the Plan as previously there had not been mention of degradation of the natural wetland ecosystem.
Would this criterion be better place in Policy FUL/04?

Part 3b – This criterion repeats the policy included in the Local Plan – Policy CC/8: Sustainable Drainage Systems.

Part 3c – Does this criterion add any value as other policies within the Plan cover this issue – FUL/01; FUL/04.

Part 3d – This is repeating an existing policy in the Plan – FUL/03

Part 3e – This is repeating Policy FUL/01

Part 4 of the policy – We repeat the comments we made at Regulation 14 that developers can only be asked to contribute outside their site (i.e., in the Parish) through a Section 106 Planning Obligation and where the Government rules can be met. As noted in our comments above, they must be:
• 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.
A developer could not be required to contribute to strengthen existing facilities for the village as a whole.

We remain unsure what is meant by ‘to support community integration in response to the requirements set out by Fulbourn Parish Council’ given that other statutory service providers will determine how their services are delivered. It is unclear whether this requirement is set out in the Plan and supported by evidence for such requirements There is a list on page 110 in the Delivery Priorities chapter of the Plan. How would a development know what is required or a planning officer know when it has been met? It is suggested that “in response to the requirements set out by Fulbourn Parish Council” is deleted from the policy.