Stapleford & Great Shelford Neighbourhood Plan Submission Version

INTRODUCTION
Carter Jonas has been instructed by Axis Land Partnerships Ltd (Axis) to respond to the Reg.16 consultation for the submission draft Stapleford & Great Shelford Neighbourhood Plan (draft S&GSNP). Axis has an interest in land within the Neighbourhood Plan area.

In summary, the Axis representations to draft S&GSNP are as follows:
• Comment on the Policy Context section of draft S&GSNP to highlight those development plan documents that are not referred to (Cambridge Southern Fringe AAP), to identify relevant emerging development plan and policy documents (emerging Greater Cambridge Local Plan), and revised national policy (NPPF December 2024).
• Comment on the housing and affordable housing references in the Vision for draft S&GSNP, which would not be addressed by the lack of policy support in the document for additional housing.
• Comment on those objectives of draft S&GSNP related to development because they are unlikely to be delivered without any support for additional residential development.
• Object to Policy S&GS 12 because it does not take into account that the land between Stapleford and Great Shelford and Cambridge is already designated as Green Belt.
• Object to Policy S&GS 13 because the proposed important views from Stapleford Cemetery (View T) and Gog Magog Way (View U) (as shown on Map 7 and described in Appendix 7) are general views of the countryside rather than a notable view of a particular feature from a public footpath or vantage point.
• Comment on Policy S&GS 17 because draft S&GSNP does not support new development that might enable the delivery of new community infrastructure.
• Object to Policy S&GS 19 because it is inconsistent with and duplicates transport policy requirements in the adopted South Cambridgeshire Local Plan and revised NPPF December 2024.
• Object to Policy S&GS 21 because the proposed Improved Landscape Area designation (as shown on Map 14) is inconsistent with and duplicates a similar countryside enhancement designation in the adopted Cambridge Southern Fringe AAP.

The draft S&GSNP will need to be in general conformity with strategic policies in the adopted South Cambridgeshire Local Plan. It is acknowledged that the Local Plan does not allow for the release of land from the Green Belt around Stapleford or Great Shelford through the neighbourhood plan process.

In due course draft S&GSNP will be examined by an Independent Examiner who will determine whether the basic conditions for a neighbourhood plan have been met. As explained in this response, it is considered that some of the policies and designations in draft S&GSNP do not meet Basic Condition (a) and are inconsistent with national policy, or Basic Condition (e) and are not in general conformity with the strategic policies contained in the development plan for the area.

At the end of the representations to each policy is a summary and the requested changes.

All references to the NPPF in these representations relate to the December 2023 version unless otherwise stated because of the transitional arrangements for neighbourhood plans contained in Paragraph 239 of the December 2024 NPPF.


REPRESENTATIONS TO DRAFT S&GSNP

Policy Context

COMMENT

Paragraphs 3.2 to 3.5 of draft S&GSNP seeks to identify the policy context for the document. It is considered that this section covers only part of the relevant policy context, and omits references to other development plan documents, to emerging development plan documents, and to national policy. This is relevant because some policies in draft S&GSNP are inconsistent with adopted and emerging development plan policies and with national policies, as set out in these representations. Those inconsistencies might not have occurred if the policy context section had provided a more comprehensive review of adopted and emerging policy.

The policy context section does not identify the adopted Cambridge Southern Fringe AAP as a relevant development plan document for draft S&GSNP. As set out in the representations to Policy S&GS 12 and Policy S&GS 21, the proposed Improved Landscape Area duplicates similar policies in the Cambridge Southern Fringe AAP but does not mention the important connection between the delivery of countryside enhancements and development contained in the AAP.

The policy context section refers to the Green Belt and highlights the extent of the Green Belt around the villages and between the villages and Cambridge. The policy section does not refer to national policy relating to the Green Belt as contained in Chapter 13 of the NPPF. As set out in the representations to Policy S&GS 12, the adopted Local Plan and the NPPF already provide strong protection from development for land located within the Green Belt, and it is unnecessary for draft S&GSNP to include similar policies to these areas.

Paragraph 3.5 provides some limited commentary on the emerging Greater Cambridge Local Plan, but other matters should have been included too. Stapleford and Great Shelford will continue to be classified as Rural Centres in the settlement hierarchy for the emerging Local Plan. The status of these villages in the settlement hierarchy reflects the good range of services and facilities within them. The emerging Local Plan identifies these villages within a new Rural Southern Cluster which seeks to connect employment growth to housing in an accessible location. The Rural Southern Cluster approach reflects the close proximity of the villages to employment including Cambridge Biomedical Campus, and the availability of a railway station, bus services and cycle routes from the villages, and the transport improvements to be delivered by the planned Cambridge South East Transport Project in the future.

The emerging Local Plan will need to be consistent with the changes to national policy contained in the revised NPPF published in December 2024. Those changes include a higher housing need figure for both Cambridge and South Cambridgeshire, that development needs should be met in full, and where exceptional circumstances exist to review and release land from the Green Belt to meet those development needs in sustainable locations. In addition, the Government has recently confirmed a commitment to further growth in the Oxford to Cambridge corridor. It is very likely that the development strategy in the emerging Greater Cambridge Local Plan will need to be updated to reflect changes to national policy and growth aspirations, and this is likely to affect land within the draft S&GSNP area.

It is considered that a more comprehensive review of the relevant policy context for draft S&GSNP would have highlighted that some policies and designations are not required.

Summary Representation
Paragraphs 3.2 to 3.5 of draft S&GSNP provide only part of the relevant policy context. The adopted Cambridge Southern Fringe AAP should be identified as a relevant development plan document. The policy context should include more detailed commentary on the emerging Greater Cambridge Local Plan and national policy. It is considered that a more comprehensive review of the relevant policy context for draft S&GSNP would have highlighted that some policies and designations are not required.

Requested Change
It is requested that the policy context section in draft S&GSNP refers to the adopted Cambridge Southern Fringe AAP and includes more detailed commentary on the emerging Greater Cambridge Local Plan and national policy.

Vision

COMMENT

The Vision for draft S&GSNP refers to addressing identified housing and affordable housing needs. The Housing Needs Assessment (AECOM March 2023) identified a high need for both social rent and affordable home ownership housing in the villages. It should be noted that affordable housing is mostly delivered in conjunction with market housing, and that rural exception schemes are typically small scale and provide a limited number of dwellings. The affordable housing requirement in the South Cambridgeshire Local Plan is for 40% of housing to be affordable from developments of 10 or more dwellings. As such, sufficient land to provide both market and affordable housing would need to be allocated to meet the identified affordable housing needs.

It would be appropriate for the Vision to seek to address those housing needs. However, as set out in this response, the draft S&GSNP does not provide any policy support for housing and affordable housing needs to be addressed through the emerging Greater Cambridge Local Plan. It appears that draft S&GSNP seeks to introduce new policy designations that are clearly intended to limit development at the villages in the future, and to restrict potential options for the growth of the villages. It is unlikely that the aspirations in the Vision to address housing and affordable housing need would be achieved without positive policy support in draft S&GSNP to actually meet those needs.

Draft S&GSNP should include an additional policy that supports the allocation of land for development at the villages through the emerging Greater Cambridge Local Plan process to meet housing and affordable housing needs.

Summary Representations
It is unlikely that the aspirations in the Vision to address housing and affordable housing need would be achieved without positive policy support in draft S&GSNP to actually meet those needs.

Requested Change
No changes are requested to the Vision.


Objectives

COMMENT

Paragraph 5.2 identifies 10 theme-based objectives for draft S&GSNP. These objectives are appropriate. It is noted that the objectives related to housing, biodiversity, community amenities and infrastructure, and countryside enhancement all refer to development, and it is assumed that additional development is necessary to support the delivery of those objectives. However, draft S&GSNP does not allocate any land for development and does not provide any policy support for development to be brought forward in the future through the emerging Greater Cambridge Local Plan process.

Draft S&GSNP should include a policy that supports the allocation of land for development at the villages through the emerging Greater Cambridge Local Plan process to deliver the housing, biodiversity, community amenities and infrastructure, and countryside enhancement related objectives.

Summary Representation
It is unlikely that those objectives that are associated with the delivery of additional development - housing, biodiversity, community amenities and infrastructure, and countryside enhancement - would be achieved without specific policy support for development.

Requested Change
No changes are requested to the objectives.


Policy S&GS 12: Protecting and Enhancing Stapleford and Great Shelford’s Landscape Character

OBJECT

Policy S&GS 12 relates to landscape character. Criteria 1(b) of this policy seeks to retain the existing area of separation between Stapleford and Great Shelford and the City of Cambridge. Criteria 4 of this policy refers to development affecting the proposed Landscape Improvement Area in Policy S&GS 21. In summary, these criteria do not take into account that all of the land between the villages and Cambridge is already designated as Green Belt, or that a Countryside Enhancement Strategy is identified in the adopted Cambridge Southern Fringe AAP.

Policy S/4 of the adopted South Cambridgeshire Local Plan seeks to maintain a Green Belt around Cambridge, with any development proposals in the Green Belt assessed against national policies contained in the NPPF. The Green Belt at Great Shelford and Stapleford is defined on the Local Plan Proposals Map Inset No.45. Stapleford Allotments fall within the land designated as Green Belt. As highlighted in Paragraph 142 of the NPPF, openness is identified as an essential characteristic of the Green Belt. Policy NH/2 of the adopted South Cambridgeshire Local Plan seeks to protect and enhance landscape character, and refers to National Character Areas. Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”.

Criteria 1(b) of Policy S&GS 12 would duplicate the openness requirement of the Green Belt designation that already applies to land between the villages and Cambridge, and landscape character is already protected by Policy NH/2 of the adopted Local Plan. It is not necessary to duplicate development plan policies and national policies, and to do so would be inconsistent with Paragraph 16(f) of the NPPF. Therefore, criteria 1(b) of Policy S&GS 12 would not meet Basic Condition (a). In addition, it is not clear what is meant by the term “existing area of separation” between the villages and Cambridge, as it is not defined in draft S&GSNP.

As set out below in the representations to Policy S&GS 21, the proposed Improved Landscape Area duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP. The countryside enhancement strategy proposed in the adopted AAP are linked to and funded by development. There are no development allocations in draft S&GSNP that would support the delivery of the proposed Improved Landscape Area in Policy S&GS 21. As also requested in representations to Policy S&GS 21, the proposed Improved Landscape Area referred to in criteria 4 should be deleted, because it is inconsistent with and duplicates an adopted development plan policy which is contrary to national policy and would not meet Basic Condition (a).

Summary Representation
The reference in Criteria 1(b) of Policy S&GS 12 to retain the existing area of separation between the villages and Cambridge is not necessary because this area is already designated as Green Belt. Criteria 1(b) should be deleted.

The proposed Improved Landscape Area, referred to in Criteria 4 of Policy S&GS 12, duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP. Criteria 4 should be deleted.

Requested Change
It is requested that criteria 1(b) and criteria 4 of Policy S&GS 12 are deleted.


Policy S&GS 13: Important Views

OBJECT

Policy S&GS 13 identifies a number of proposed important views around the villages, which are to be maintained and enhanced as part of any development proposals. Those proposed important views are listed in Policy S&GS 13, shown on Map 7, and described in Appendix 7. It is noted that the majority of land at the edge of the villages fall within a proposed important view.

Axis’ land interest falls within the following identified views: New countryside park between Haverhill Road and Hinton Way (View O); Gap between 27 and 31 Mingle Lane (View S); Stapleford Cemetery (View T); and from Gog Magog Way (View U).

Axis has instructed The Landscape Partnership to provide an independent
appraisal of the identified Important Views O, S, T and U. The Landscape Rebuttal Statement is provided in Appendix A. The Visualisations of those Important Views is provided in Appendix B.

In summary, it is concluded in the Rebuttal Statement that no clear methodology has been provided with Policy S&GS 13 as to how the Important Views have been identified and what, if any, qualities they need to have to qualify. There is no public footpath or bridleway across the land off Hinton Way, and there are no public footpaths or bridleways within the proposed important views at Views O, S, T and U. The proposed important views at Views O, S, T and U do not take into account the changes to landscape and visual character that are taking place as a result of the retirement village development and associated countryside park at land of Haverhill Road, which is currently under construction. The proposed important views at Views O, S, T and U do not take into account the future potential changes to landscape and visual character that are likely to arise from the Cambridge South East Transport project (a new busway to the east of Stapleford with stops at Haverhill Road and Hinton Way), or the draft allocation for residential development off Mingle Lane in the emerging Greater Cambridge Local Plan (draft Policy S/RSC/HW for 100 dwellings).

Paragraph 041 (Ref ID: 41) of the Planning Practice Guidance states that “It [neighbourhood plan policies] should be concise, precise and supported by appropriate evidence”. The evidence put forward to explain and justify the proposed important views at Views O, S, T and U is not robust, and as such these proposed designations do not have regard to national policy and would not meet Basic Condition (a). It is considered that Views O, S, T and U are general views of the countryside, and typical of other similar views on the edge of villages elsewhere in South Cambridgeshire.

Policy NH/2 of the adopted South Cambridgeshire Local Plan seeks to protect landscape character and the landscape of the National Character Areas. Policy HQ1 identifies the design principles for development, which includes preserve and enhancing the character of the area and responding to the site context in the wider landscape (criteria a) and providing high quality landscape (criteria m). Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. The landscape character around the villages, and at Views O, S, T and U, is already protected by Policy NH/2, and high quality landscaping is required by Policy HQ1 of the adopted Local Plan. It is not necessary to duplicate development plan policies related to protecting landscape character, and to do so would be inconsistent with Paragraph 16(f) of the NPPF and would not meet Basic Condition (a).

It might be helpful for the Neighbourhood Plan Group to review the Examiner’s Report for the Fulbourn Neighbourhood Plan (published April 2022), which also considered proposed locally important views for that document - see Paragraphs 7.33 to 7.35. In summary, the draft Fulbourn Neighbourhood Plan identified multiple viewpoints into and out of the village that should be protected. The Examiner concluded that those proposed viewpoints were general in nature, the importance of those views to the surrounding landscape was not explained, and the relationship between the views and the settlement was not identified. The Examiner recommended that all of the proposed locally important viewpoints be deleted. It is suggested that the outcome should be the same for the proposed important views identified in Policy S&GS13, including Views O, S, T and U.

It is noted that no other made neighbourhood plans in South Cambridgeshire include a policy to protect identified views. A consistent approach should be applied for all neighbourhood plans within the same district.

Summary Representation
The proposed important views at Views O, S, T, and U are general views of the countryside only, do not contain any particularly notable landscape or topographic features, and the assessment of those views does not explain why those views are important to warrant special protection. The adopted South Cambridgeshire Local Plan already contains policies that seek to protect landscape character and policies that require high quality landscaping to be provided with development proposals, and it is not necessary to duplicate those policies in draft S&GSNP. It is requested that proposed Views O, S, T and U are deleted.

Requested Change
It is requested that the proposed important views at New countryside park between Haverhill Road and Hinton Way (View O), Gap between 27 and 31 Mingle Lane (View S); Stapleford Cemetery (View T), and from Gog Magog Way (View U) are deleted from Policy S&GS13 and from Map 7, and that references to these views are removed from Appendix 7.


Policy S&GS 17: Delivering Community Infrastructure Priorities Alongside New Development

COMMENT

Policy S&GS 17 relates to the delivery of community infrastructure through planning obligations, and identifies a specific need for informal open space and play space.
Policy TI/8 of the adopted South Cambridgeshire Local Plan seeks planning obligations from development for the delivery of necessary infrastructure. Paragraph 57 of the NPPF sets out the three tests for planning obligations. Section ID.23b of the Planning Practice Guidance provides further national guidance on planning obligations. As set out in Paragraph 16(f) of the NPPF, it is not necessary for neighbourhood plans to duplicate development plan policies or national policies, and therefore it is suggested that the first part of Policy S&GS 17 relating to planning obligations could be deleted.

Criteria 3 of Policy S&GS 17 appears to imply that the community infrastructure necessary to support a development is provided on that development site. The CIL Regulations, the supporting text to Policy TI/8 of the adopted South Cambridgeshire Local Plan, and Section ID.23b of the Planning Practice Guidance all allow for planning obligations to be pooled to meet strategic requirements and for obligations to be spent on off-site infrastructure projects. Criteria 3 of Policy S&GS 17 is inconsistent with regulations, national policy and development plan policy, and should be amended or deleted.

Criteria (a) of Paragraph 97 of the NPPF requires planning policies to plan positively for the provision of community facilities including open space. Policy S&GS 17 of draft S&GSNP identifies a need for informal open space and play space as a priority. However, as noted elsewhere in this response, draft S&GSNP does not provide any policy support for residential development that might deliver planning obligations for new community infrastructure. Policy S&GS 17 identifies community infrastructure needs, but does not explain how that infrastructure would actually be delivered without support from additional development. It is considered that Policy S&GS 17 would be ineffective at delivering community infrastructure in the absence of development or specific policy support for additional development, and it is likely that the identified needs for informal open space and play space would remain undelivered which would be a negative outcome. For these reasons, Policy S&GS 17 is inconsistent with Paragraph 97(a) of the NPPF, and as such would not meet Basic Condition (a).

Summary Representation
It is not necessary for Policy S&GS 17 to duplicate development plan policies or national policies relating to planning obligations. The first part of Policy S&GS 17 relating to planning obligations could be deleted.

Criteria 3 of Policy S&GS 17 is inconsistent with regulations, national policy and development plan policy, in respect of pooled and off-site contributions, and should be deleted.

Policy S&GS 17 would be ineffective at delivering community infrastructure in the absence of development or specific policy support for additional development. The identified needs for informal open space and play space would remain undelivered, which would be an outcome that is inconsistent with national policy.

Requested Change
It is requested that the first part of Policy S&GS 17 relating to planning obligations for community infrastructure is reviewed in order to determine whether it is necessary to duplicate adopted development plan policies and national policy for these matters.

It is requested that Criteria 3 of Policy S&GS 17 is deleted.

The references to identified needs for informal open space and play space should be retained in Policy S&GS 17, but it is requested that the policy includes a mechanism for the delivery of these community infrastructure items.

Draft S&GSNP should include policy support for additional development that could support the delivery of community infrastructure.


Policy S&GS 19: Managing the impacts of new development in the Plan area with respect to the movement of people and vehicles

Policy S&GS 19 of draft S&GSNP sets out the policy requirements for developments that have an impact on traffic. Policy TI/2 of the adopted South Cambridgeshire Local Plan deals with similar transport matters, including mitigating transport and environmental impacts. However, Policy TI/2 also refers to document requirements to identify transport impacts and sustainable transport options to address impacts. Chapter 13 of the NPPF and Section Id.42 of the Planning Practice Guidance provide detailed policy requirements for assessing the transport impacts of development. Paragraph 115 of NPPF 2023 (and Paragraph 116 of NPPF 2024) states that development should only be refused on highways grounds if there would be an unacceptable impact on highway safety, or the residual cumulative impacts on the road network would be severe.

Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. It is considered that Policy S&GS 19 duplicates parts of Policy TI/2 of the Local Plan and parts of national policy on sustainable transport contained in Chapter 13 of the NPPF, which is not necessary. Policy S&GS 19 does not mention sustainable transport options to address transport impacts, and is inconsistent with Policy TI/2 and Paragraphs 109, 114 and 116 of the NPPF. Policy S&GS 19 is inconsistent with Paragraph 115 of the NPPF in terms of the highway impacts being severe. Policy S&GS 19 would be contrary to national policy, and as such would not meet Basic Condition (a). It is requested that Policy S&GS 19 is deleted or amended to be consistent with development plan policy and national policy on transport matters.

Summary Representation
Policy S&GS 19 duplicates development plan policies and national policies on transport, and would be inconsistent with Paragraph 115 of the NPPF, both of which would be contrary to national policy and would not meet Basic Condition (a).

Requested Change
It is requested that Policy S&GS 19 is deleted or amended to be consistent with development plan policy and national policy on transport matters.


Policy S&GS 21: Delivering Stapleford and Great Shelford’s Improved Landscape Area

OBJECT

Policy S&GS 21 of draft S&GSNP seeks to designate all of the land on the eastern edge of Stapleford and Great Shelford as an Improved Landscape Area, for the purpose of countryside enhancement measures. The proposed Improved Landscape Area is shown on Map 14.

Policy CSF/5 of the adopted Cambridge Southern Fringe AAP, which is part of the adopted development plan for South Cambridgeshire, already designates the same land for a countryside enhancement strategy. The land designated by Policy CSF/5 is shown on Inset E of the adopted AAP. Policy CSF/5 provides additional detail of the landscape, planting and access measures required. The countryside enhancement strategy proposed in the adopted AAP are linked to and funded by development. There are no development allocations in draft S&GSNP that would support the delivery of the proposed Improved Landscape Area in Policy S&GS 21, and without an effective delivery mechanism this proposed designation would not be implemented. The fact that the proposed Improved Landscape Area is unrelated to development and contains no delivery mechanism makes it inconsistent with Policy CSF/5 in the adopted Cambridge Southern Fringe AAP.

Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. It is clear that the proposed Improved Landscape Area designation in Policy S&GS 20 duplicates Policy CSF/5 of the adopted Cambridge Southern Fringe AAP, which is not necessary. Policy S&GS 21 would be contrary to national policy, and as such would not meet Basic Condition (a).

The second paragraph of Policy S&GS 21 requires planning obligations for landscape initiatives listed in Paragraph 11.32. Most of the listed landscape improvements are located on private land, and some are related to specific development proposals. It is not clear whether there is landowner agreement for these landscape improvements, and how they would be delivered on private land that is unrelated to a particular development. The landscape improvements for a particular development should be determined in a site specific policy for an allocation and at planning application stage, and contributions should not be sought for potentially unrelated landscape projects. The second paragraph of Policy S&GS 21 is not consistent with national policy on planning obligations contained in Paragraph 57 of the NPPF. In addition, Paragraph 10.46 provides the supporting text to Policy TI/2 of the adopted South Cambridgeshire Local Plan, and identifies landscaping and the historic landscape as matters where planning contributions may be required. It is not necessary for Policy S&GS 21 to also seek contributions towards landscape improvements. Therefore, the second paragraph of Policy S&GS 21 would be contrary to national policy, and as such would not meet Basic Condition (a).

Summary Representation
The proposed Improved Landscape Area duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP. It is requested that the proposed Improved Landscape Area in Policy S&GS 21 and shown on Map 14 is deleted.

The planning obligations for landscape initiatives referred to in Policy S&GS 21 and listed in Paragraph 11.32 are mostly unrelated to development and delivery is uncertain when it involves unrelated private land. It is requested that the second paragraph of Policy S&GS 21 is deleted.

Requested Change
It is requested that the proposed Improved Landscape Area in Policy S&GS 21, and shown on Map 14, is deleted.

It is requested that the second paragraph of Policy S&GS 21 is deleted.