Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 58686

Received: 13/12/2021

Respondent: Wates Developments Ltd

Agent: Boyer Planning

Representation Summary:

Land west side of London Road, High Street, Fowlmere (HELAA site 40116)

Development should be assigned across settlement hierarchy, with development proportionate to provision of services and facilities and public transport network. Policy direction includes restrictions on indicative maximum scheme sizes for each settlement tier. Coupled with overall development strategy for only small number of allocations within rural area, ability for sustainable developments to come forward is overly restrictive.

Applying restrictions on development is not considered justified, as sustainability of settlements and availability of suitable sites can vary between settlements within same tier. More appropriate to identify additional site allocations within villages, considering each rural settlement on individual basis. Government’s objective of significantly boosting supply of homes (NPPF Paragraph 60).

New development can increase sustainability of existing settlements through provision of additional, or enhancing existing, services and facilities, and have a positive impact upon long term viability through supporting rural schools and facilities.

Fowlmere is “Group Village”. Concerned by lack of assessment in terms of its ability to accommodate growth.

Settlement hierarchy divides Group Villages into two key categories - with and without good transport links. Significant concerns with simplistic approach to categorising settlements and their ability to accommodate development.

Group Villages with very good public transport were assessed using points system, with only those considered to have good existing or proposed sustainable transport links assessed further in terms of their ability to accommodate development.

Failure of evidence base to consider all modes of transport and bus services within Fowlmere and its connectivity to surrounding settlements represents a flaw. Modes should not be viewed in isolation, rather should be viewed collectively, bus and train links. Resulted in sites within Fowlmere not being properly considered.

Fowlmere is desirable and sustainable employment location, not reliant on private car and sustainable modes of transport are available.

To ensure employment growth is supported by sufficient housing Fowlmere should accommodate housing sites, to meet criterion c) NPPF Paragraph 82. Land West of London Road Fowlmere lies adjacent to the employment opportunities at Manor Farm Business Park, offers a sustainable and suitable location for development and is immediately available.

Full text:

Development should be assigned across the settlement hierarchy, with development proportionate to the provision of services and facilities and the public transport network. The proposed policy direction relating to the settlement hierarchy includes restrictions on the indicative maximum scheme sizes that will comprise acceptable windfall development for each settlement tier. Coupled with the overall development strategy for only a small number of site allocations within the rural area, the ability for sustainable developments to come forward is overly restrictive.

Paragraph 009 (Reference ID: 67-009-20190722) of the Planning Practice Guidance (PPG) states “a wide range of settlements can play a role in delivering sustainable development in rural areas, so blanket policies restricting housing development in some types of settlement will need to be supported by robust evidence of their appropriateness”. It is not considered that there is robust evidence to demonstrate that the policy direction putting a limit on development in the rural areas is appropriate.

Applying restrictions on the maximum amount of development that is appropriate to any particular tier is not considered to be a justified approach, as the sustainability of settlements and the availability of suitable sites for development can vary between settlements within the same tier. A more appropriate strategy would be to identify additional site allocations within the villages, considering each of the rural settlements on an individual basis. This would assist in meeting the Government’s objective of significantly boosting the supply of homes by ensuring that that a sufficient amount and variety of land can come forward where it is needed (NPPF 2021; Paragraph 60).

It should also be acknowledged that new development can increase the sustainability of an existing settlement through the provision of additional services and facilities, or through enhancing existing services and facilities. New development that is well related to the existing settlement can also have a positive impact upon the long term viability of a place through indirect spending from future occupiers and through supporting rural schools and facilities.

Fowlmere - Settlement Hierarchy - Group Village
Fowlmere is identified in the Settlement Hierarchy as a “Group Village”. In accordance with S/SH, the Group Villages can accommodate indicative maximum scheme size of 8 dwellings, and exceptionally consist of up to about 15 dwellings where this would make the best use of a single brownfield site.

Notwithstanding our fundamental concerns with regards to the lack of development allocated to the Villages and the overly prescriptive restrictions on the quantum of development to come forward within the various tiers of the settlement hierarchy, we are also concerned by the lack of assessment given to Fowlmere in terms of its ability to accommodate growth.

The settlement hierarchy divides the Group Villages into two key categories, those with good transport links and those without good transport links. It is assumed that this division of the Group Villages is as a result of the findings within the transport evidence base, notably the Existing Transport Conditions Report (2020). We have significant concerns with regards to this approach which appears to adopt a simplistic method of categorising settlements and their ability to accommodate development.

Those Group Villages identified as benefitting from very good public transport access were subsequently assessed in terms of their ability to accommodate rural allocations for housing (as confirmed through the Councils’ Development Strategy Topic Paper 2021). Whilst it is noted on Page 263 of the Development Strategy Topic Paper 2021 that all Group Villages were assessed using the points system, only those considered to have good existing or proposed sustainable transport links were assessed in further detail in terms of their ability to accommodate development.

Fowlmere was not further assessed as it was not considered to benefit from very good transport links. We disagree with this conclusion and consider this to be an omission in the Councils’ assessment as a result of overlooking a key bus service within the settlement, as discussed below.

The Councils’ Existing Transport Conditions Report (2020) fails to identify a bus service which serves Fowlmere (Stagecoach 915). This bus service provides frequent links between Cambridge/Trumpington Park and Ride and Royston. At particular points in the day, bus services 915 and 31 collectively service Fowlmere with two buses an hour.

Bus Service 915 Bus Service 31
06:46 -
07:46 07:27
08:46 -
09:46 09:37
10:46 -
11:46 11:07
12:46 12:37
13:46 -
14:46 14:07
15:46 -
17:22 -
18:22 -
19:22 -

This bus route also connects Fowlmere with nearby Melbourn and Foxton, offering existing and future residents the ability to access a train station. It should also be noted that Fowlmere is a 6 minute journey to Foxton, which benefits from a train station and busway, and also a 9 minute journey to Melbourn, which also benefits from a train station. Fowlmere therefore represents a sustainable location for accommodating development.

A number of the Group Villages that are considered to benefit from good transport links, including Longstanton, are only currently serviced by an hourly bus service into Cambridge, which is less frequent than Fowlmere (which is occasionally throughout the day serviced by two bus services). Fowlmere is also located 2.6 miles from the train station in Foxton, which provides frequent links with Cambridge City. It is therefore unclear why Fowlmere has not been included within the Group Villages considered to benefit from good transport links.

The Councils’ Development Strategy Topic Paper 2021 clearly states that only those sites that were tested in the HELAA and identified as potential development options in the better served villages were subsequently subject to site specific consideration for allocation and for sustainability appraisal.

It is strongly considered that the failure of the evidence base to consider all modes of transport and bus services within Fowlmere and its connectivity to the surrounding settlements represents a flaw in the overall settlement assessment. Modes of public transport should not be viewed in isolation, rather should also be viewed collectively, with future residents being able to use both bus and train links to travel across the Greater Cambridge area, rather than a single mode of transport. This has subsequently resulted in sites that are being promoted within Fowlmere not being properly considered for development and not being subject to an independent site assessment.

Employment Opportunities
It is acknowledged that an existing employment site off The Way, Fowlmere, is subject to a pending Outline planning application for mixed use development comprising the demolition of the existing buildings and the erection of 45 dwellings and a new office building (reference 21/00542/OUT).

A large proportion of this employment site was previously occupied by Welding Alloys Ltd. However, Welding Alloys has moved its production element of the business to France which has left an extensive vacancy of buildings on site. The buildings on the site are understood to be purpose built for Welding Alloys and despite enquiries during the marketing of the site, the units have not been desirable to new potential occupiers, with more suitable premises elsewhere, including other premises within Fowlmere.

Despite the lack of suitability of the existing employment site leading to proposals for redevelopment, the Outline planning application includes a new office building as part of the scheme, which will be a modern and fit for purpose building. This demonstrates that Fowlmere remains a desirable location for new employment.
The desirability and suitability of Fowlmere as an employment location is reinforced by the presence of long-standing employers within the village. One of these is Ion Science (a world leader in gas detection equipment and research), who has been a key employer in Fowlmere since 1989.

In August 2021, planning permission was granted (reference 21/02683/FUL) for the erection of a new 3,050 sq.m Science Research and Development Office for Ion Science at the Butts Business Centre on the Manor Farm Business Park. The new facility will supplement production and management options at the company’s existing headquarters.

Ion Science is an established company and values Fowlmere as an employment location and are committed to staying there. The provision of the new Science Research and Development Office will allow Ion Science to continue operating in the local area and will provide additional jobs. Despite the proposed redevelopment of the existing employment site off The Way, it is evident that Fowlmere is a desirable employment location.

As well as desirable, Fowlmere is also a sustainable employment location. This is demonstrated through the car parking thresholds for the recently approved Ion Science application (21/02683/FUL). The required parking standard for the size of unit was 29 spaces, whilst the application was approved on the basis of 17 car parking spaces, taking into consideration the travel patterns of existing Ion Science employees. This demonstrates that access to Fowlmere is not reliant on the private car and sustainable modes of transport are available.

Fowlmere is an employment destination and a desirable location for companies, as shown through Ion Science’s desire to retain within the settlement. To ensure that employment growth is supported by sufficient housing, Fowlmere should accommodate housing sites, failing which could be at risk of falling short of meeting criterion c) of Paragraph 82 of the NPPF (2021). Land West of London Road Fowlmere lies adjacent to the employment opportunities at the Manor Farm Business Park, offers a sustainable and suitable location for development and is immediately available.