Fulbourn Neighbourhood Plan - submission version

Comment

Representation ID: 59360

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/10 Rural Exception Sites

Adopted Local Plan Policy H/11 already provides an up-to-date policy for the delivery of such schemes. We do not think that these criteria could be implemented without full justification.

Part 1d – This repeat what is already in Policy FUL/01 and FUL/04.

Part 2 – There would need to be clear justification of why this criterion should remain. The NPPF is clear that such exceptions should be allowed to ensure a housing scheme is viable. (NPPF 2021 paragraph 78). The Local Plan policy also is clear that allowing some market housing on rural exception sites on viability or deliverability grounds is acceptable. Our housing team has commented that on deliverability grounds it may be that a landowner may not release the land for affordable housing unless they are allowed market housing on the site.

Comment

Representation ID: 59361

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/11 -Housing Design Quality

The supporting text to this policy would have benefited from having more justification for all of the criteria included. They cover a range of different design considerations and would impact on the viability of any scheme.

Part 1b; 1f; 1h; 1i - These appear to be new criterion included in the Plan since the Regulation 14 consultation.

The inclusion of criteria that support sustainable construction – 1a, 1b and 1c is supported.

Part 1g - We are unsure as to how this adds value to the existing Local Plan car parking policy which has a design-led approach? Policy TI/3: Parking Provision.

Comment

Representation ID: 59362

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/12 – Employment Development

Part 1 – The first part of this section is simply repeating the Local Plan Policy E/12.

Part 1a - Should this be cross referring to FUL/16? This is stating that all development no matter the scale will have to clearly show its commitment. It is not clear how an applicant would demonstrate this and how a planning officer would know that it could be achieved? The policy is not explaining how to measure this clearly, for example through the submission of a Transport Assessment?

Part 1b - The requirement that there should be no increase in heavy goods vehicle movement is unreasonable given that developments outside the Neighbourhood Area could result in additional movements. Transport assessments should perhaps be used to demonstrate that the transport impact is acceptable.

Part 1c – Whilst recognising that heavy vehicles may impact the smaller roads within the parish is it realistic to expect new development to mitigate any adverse impacts associated with vans too. Surely this would restrict the types of employment that would be acceptable within the parish. There perhaps needs to be a definition of ‘heavy vehicle’ in the glossary and the supporting text.

Part 1d – Is it realistic to require no loss of character and visual amenity from an employment development with some level of car parking and transportation? Any new development is likely to require some car parking for workers and visitors and therefore will generate some traffic, so it is unreasonable to expect no increase in traffic movement because of new development?

Part 2a - This criterion does not define what is meant by heavy vehicles – it could be difficult for a development management officer to interpret what is meant by this term when determining an application for employment in the parish. Who would define what is meant by requiring regular heavy vehicles – once a week? one a day? What is regular? It is also open to interpretation what is meant by the ‘village boundary’ and ‘direct access to the road network’.

Part 2b - How would such a policy be achieved as banning heavy lorries from any streets is outside of the role of a planning policy.

Part 2c – How would you define adequate planted edges? How would a planning officer considering a planning application be able to determine if planting is adequate? How does it differ from other landscape policies in the Plan? FUL /01 part 1 or FUL/04 –parts 2a and 2b?

Comment

Representation ID: 59363

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/13 Large Employment Sites

We would recommend that an inset map is included showing the employment sites mentioned in this policy. It is relying on local knowledge for their location otherwise.

Part 2 - The policy is more stringent than Local Plan Policy TI/2 which effectively requires a Transport Assessment and Travel Plan for all development on the two employment sites referred to. The requirements are potentially overly onerous -for example where development is small scale the addition of a new entrance area or a new plant area would be required to provide this.

Part 1 - The Plan does not need to mention that employment development should comply with relevant policies in the Local Plan.

Part 2 –What is’ accepted best practice’? Who would know what this was ‘at the time of an application’? Explanations for this is not included in the supporting text.

The policy mentions clear responsibilities for monitoring but by whom? It might be more appropriate to state that approvals will be conditioned to require the implementation and monitoring of travel plans.

Comment

Representation ID: 59364

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/14 –Community Facilities

Part 1 – This policy is simply repeating the Local Plan policy that protects village services and facilities and this does not need to be repeated in the Plan (Policy SC/3)

Part 2 – It is not necessary to include the wording after (see Figure 19) relating to standards required by Sport England.

The landowner of this field has been consulted over this proposal but does not indicate whether he/she is happy for the recreation ground to expand into this area? If the landowner is not willing for this to take place it may make this policy aspiration unviable/ unachievable.

Part 3 – This criterion seeks to direct the District Council to secure funding for existing facilities in preference to the creation on new ones. It is accepted that using section 106 contributions to extend existing facilities will, in many cases, be the most logical and cost-effective way to mitigate the impact of a development. However, there are times when a new standalone community facility is required, and the decision will always rest with the planning decision taker having regard to the specific circumstances of the proposal.

Comment

Representation ID: 59365

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Policy FUL/15 –Healthcare Facilities

It has not been clearly stated in the Plan whether the current GP practice and / or the Local Heath authority are supportive of the proposals in this policy. Within the consultation statement there is an indication that there have been discussions with the GP practice and that they support the proposals. In part 3 of this policy it states that there is an expectation that the new healthcare will be with the current GP practice.

Comment

Representation ID: 59366

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

15 Delivery Priorities

Through preparation of the Neighbourhood Plan a number of spending priorities have been identified by the community to improve the lives of people living and working in the parish. Both the Local Plan and national planning guidance recognises that not all developments will be able to sustain all policy requirements expected of it. Where planning obligations are negotiated on the grounds of viability some infrastructure requirements need to be given a greater level of priority than others and in some cases contributions towards the lower priority items may ultimately not be secured. This Delivery Priorities list is therefore a helpful guide to the District Council when considering viability as part of the decision-making process.

Comment

Representation ID: 59367

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Appendix 2 - Trees

A new appendix has been added to the Plan including a list of native, specimen and ornamental trees which are considered appropriate for Fulbourn. It is not clear who decided upon the trees to be included in this list? Our Trees officer has no issues with the species choice but would not recommend limiting new tree planting to only species in the list. We have concerns that disease can decimate an entire population of trees as has happened with Horse chestnut, Elm, Ash and to some extent Oak. More important is seeking trees which benefit ecology, are resilient in the face of climate change and are not invasive or cause harm. This appendix may need updating regularly to reflect the changing climate.

If the list is to be retained, then all trees must include their botanical name to avoid confusion.

Comment

Representation ID: 59368

Received: 17/01/2022

Respondent: South Cambridgeshire District Council

Appendix 3 – Glossary

Biodiversity Net Gain is included in the glossary – the reference to the Environment Bill (2020) needs to be updated to the Environment Act 2021.