Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58243

Received: 13/12/2021

Respondent: Cambridgeshire & Peterborough NHS Foundation Trust

Agent: Savills

Representation Summary:

Cambridgeshire and Peterborough NHS Foundation Trust seek a change to the Green Belt boundary at the Fulbourn Hospital site to exclude land in the northern part of the site from such a designation having regard to the existing built built up character of the site and its relationship to Tescos and Capital Park.

Full text:

Savills (UK) Ltd are instructed by Cambridgeshire & Peterborough NHS Foundation Trust to make the necessary and relevant representations to the Greater Cambridge Local Plan – First Proposals Document which has been published for consultation.
We appreciate that the consultation documents reflect the fact that we remain at the early stage of plan preparation and that the document only sets out the broad policy direction of the new Joint Local Plan but nevertheless remains important for the Trust to engage in the plan making process
Policy GP/GB “Protection and Enhancement of the Cambridge Green Belt”
One of the key policy directions within the new Joint Local Plan for Greater Cambridge is envisaged to be the retention of the Green Belt and the relevant policy justification that accompanies this designation. This follows on from references to Green Belt policy within National Planning Policy Guidance which sets out specific requirements for how planning proposals in these areas should be considered as well as providing the reasons why Green Belt designation applies to certain areas.
Paragraph 138 of the NPPF states:
“Green Belt serves five purposes:
a) to check the unrestricted sprawl of large built-up areas;
b) to prevent neighbouring towns merging into one another;
c) to assist in safeguarding the countryside from encroachment;
d) to preserve the setting and special character of historic towns;
and e) to assist in urban regeneration, by encouraging the recycling of derelict and other urban land”.
Paragraph 140 then states that Green Belt boundaries should only be altered where exceptional circumstances are fully evidenced and justified, through the preparation or of updating of plans. Consequently, the preparation of a new joint Local Plan provides the opportunity to review such boundaries and in such circumstances is entirely appropriate for the Trust to respectfully suggest the need to amend the Green Belt boundary at Fulbourn Hospital on the basis of the contribution (or not) it makes to Green Belt purposes.
The Trust is the landowner of land at Fulbourn Hospital. The site is bounded to the west by Yarrow Road, by Cambridge Road to the south and by Tescos and Fulbourn Old Drift to the north. The Green Belt designation covers the whole of the site despite a significant amount of built form located in the northern part of the site and planning permission having been granted on 30 April 2021 for a new Resource Centre. This latter development was granted through a demonstration of Very Special Circumstances having regard to the presence of the Green Belt designation and its inclusion as part of the Development Plan.

It is the view of the Trust that legitimate questions should be asked about the appropriateness of including the Fulbourn Hospital site within the Green Belt given the significant amount of built form in the northern part of the site and the consequent character of the site in question. It is also relevant to refer to the commentary contained within the evidence base prepared in support of the initial work on the Local Plan. Topic Paper 5 is the Greater Cambridge Green Belt Assessment report and Appendix B to that document specifically relates to Site CH15 which is the land parcel including Tescos, Fulbourn Hospital and Capital Park immediately east of the hospital site. It is the view of the Trust that the largely built up nature of certainly the northern part of CH15 is such that it merits removal from the Green Belt.

Site CH15 is referred to in Appendix B to the Green Belt Assessment (Appendix B – Cambridge – Arbury to Cambridge North”)

Indeed the Green Belt assessment for Site CH15 states:

“While the southern area of the parcel is more open, the parcel contains more significant urbanising elements including Fulbourn Hospital, Capital Park and a Tescos superstore”. The whole of land parcels CH15 lies adjacent to the existing built up area and it is acknowledged that the presence of a tree line and the edge of the built up area along Yarrow Road means that the views are dominated by urban development which is certainly not a characteristic in our view having regard to Green Belt designation.
Having regard to the three purposes of including land within the Green Belt, we make comment on each of these three purposes in italics below:

Cambridge Purpose 1 - To preserve the unique character of Cambridge as a compact, dynamic city with a thriving historic centre
The Green Belt assessment acknowledges that the contribution is limited. It states that the parcel has some relationship with the urban area and we would certainly confirm that is the case since it lies adjacent to the built up area. The assessment concludes that the parcel makes a “relatively limited contribution to Cambridge Purpose1”

Cambridge Purpose 2– to maintain and enhance the quality of Cambridge’s setting.
It is certainly the case that Fulbourn Hospital, Tescos and Capital Park weaken the rural character of this edge of the City and whilst it is acknowledged that the land falls within Fulbourn Conservation Area this do not relate to land being included within the Green Belt nor the justification for it. Whilst it is the case that the southern parts of the land parcel have more open elements, it is the built up areas to the north and that character which dilutes the importance of including the land within the Green Belt. It cannot be the case that the built up area contributes positively to the character and the landscape and setting and thus there is no case for built up areas such as those being included within Green Belt designation.

Cambridge Purpose 3– to prevent communities in the environs of Cambridge from merging into one another and with the City.
It is the case that the Green Belt assessment confirms that the contribution in this context is “relatively limited” because the land forms an area between Cherry Hinton and the village of Fulbourn where an urbanising development reduces any perceived separation.
It is clear that the Council’s technical assessment work which has looked at the contribution that Parcel CH15 makes to the Green Belt has led to a conclusion which places the land parcel CH15 in the “Moderate High” harm rating as shown in Figure 4.4 below. It is our view that that the character of the land parcel is such that it cannot be classed as a single site since there are clear differences between the more open southern areas at Cambridge Road and the far more built up areas to the north. It is considered that the built up areas to the north of the land parcel including the footprint of the buildings at Fulbourn Hospital should be removed from the Green Belt

The attached plan (taken from the Adopted Local Plan 2018) shows the suggested revision to the Green Belt boundary at it affects the Fulbourn Hospital site.