MERTON COLLEGE
On behalf of Merton College we object to the draft of the GVDG for the following reasons;
Guidance - 4.2:
This states 'New Development should respect the 200m buffer zone to Gamlingay woods proposed ion the draft Neighbourhood plan (cons 2019) supported by the Wildlife Trust. However, the Gamlingay neighbourhood plan has yet to be published for the consultation and adopted. The 'Note to the Reader' section of the VDG clarifies the 'SPD cannot make new planning policy' and therefore there is currently no policy basis for a 200m buffer zone and this has no status.

Guidance4.3

Merton College owns 'Log Field' along with the adjacent pastureland, which identified as a Sensitive Village Edge (zone 3). Merton College OBJECTS to this designation for the following reasons;

1.The design guide clarifies the purpose and scope of the guide, and states 'the GVDG has been prepared to amplify and build on the requirements set out with thein the policy HQ/1: Design Principles in the adopted 2018 local plan, as well as supporting the other policies in the local plan which relate to the built and natural character, and distinctiveness of South Cams' Policy HQ/1: Design principles clarifies 'All new development must be of high quality design, with a clear vision as to the positive contribution the development will make to its local and wider context' Both the design guide and the Policy HQ1 are clearly about ensuring an appropriate quality of design that has regard to setting of sites. Therefore, it is inappropriate for the design guide to introduce land designation principles, such as 'sensitive village edges' and this goes beyond the scope of policy HQ1 and the SPD.

2. in relation to the Log Field and adjacent pastureland there is no explanation:
- Why is this are sensitive?
- How it differs from other edges of the village?
- How the sensitivity has been assessed?
- What was the methodology for the selection of Sensitive Village Edges and by what criteria?
Without this justification the identification of SVE is unfounded.
3. the adopted Local Plan identifies important village gaps where land that enhances the setting, character and appearance of a village and retains a sense of connection between the village and its rural origins and surroundings should be kept open and free from development. the Log Field and adjacent pastureland is not a designated Important Village gap and the proposal is introducing a designation which should be addressed and examined through the statutory local plan process.
4. the note to the reader section of the VDG states the SPD will be a material consideration in the determination n of planning apps in Gamlingay and goes onto clarify that the SPD cannot make a new planning policy, however, the proposed Sensitive Village Edge designation of areas which should be maintained would create new planning policy, contrary to the purposes to the SPD. Moreover, this statement is stringent than criterion a. of policy HQ1, which requires development proposals to preserve and enhance character.
5. The log field along with the adjacent pastureland was promoted by the District Council and the Parish Council for designation as a Local Green Space through the preparation of the adopted Local Plan on the grounds 'The Council considers that this site should remain as a LGS. This site was submitted by Gamlingay Parish Council during the issues and options 2 consultation in which they stressed the value the local community placed upon the site for its beauty, tranquillity and richness of wildlife. It is seen as a Green Lung, providing a buffer between Gamlingay and Dennis Green. It has high recreational value since it is close to an area of housing with few green spaces. The council considers that the site meets test for LGS designation using the evidence from the Parish Council and was included in the proposed submission local plan where there was much local support. This was challenged by landowners at the public examination on the grounds that the are was not of particular significance and did not meet the requirements of the NPPF of being; demonstrably special to a local community and holds a particular local significance, for example, because of its beauty, historic significance, recreational value, tranquillity or richness of its wildlife; and where the green area concerned is local in character and is not an extensive tract of land. Following assessment by the Inspector the local green space designation was removed, save for the of field area, which has public access.
6. The log field along with the adjacent pastureland is not subject to any national designations and there are no public rights of way running through or immediately adjacent to the site boundaries. the site is within the Greensand Ridge Landscape Character Area which is a swath of land on the Beds border, described as 'This is small character area associated with the undulating dip slope of the lower greensand ridge. It is drained by small streams and there are some locally steep slopes. The fairly wooded landscape is interspersed with medium sized arable fields, small areas of pasture and market gardening. There are also small areas or remnant parkland and heath. Despite the presence of some worked out gravel pits, the area retains a predominantly rural character. This is not a particularly remarkable character area and the site does not exhibit any unique landscapes qualities. The site is in a discreet location screened by established hedging and trees which restrict public views into the site. Therefore, given the assessment of the site, its designation as a Sensitive Village Edge is not justified.

Guidance 4.4

This states 'New development shuld preserve key views to and from the village (Map and Fig 7 below). This conflicts with policy HQ/1 of the adopted Local Plan 2018 which sets out in section 1 'As appropriate to the scale and nature of the development, proposals must:
a) preserve or enhance the character of the local urban and rural area and respond to its context in the wider landscape
b) Conserve or enhance important natural and historic assets and their setting.'

There is also no explanation of how the sensitivity of the views have been assessed and by what criteria.