Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 59083

Received: 13/12/2021

Respondent: Scott Properties

Representation Summary:

Land at Frog End, Shepreth (HELAA Site 40085)

Scott Properties considers that the Plan does not distribute sufficient growth to villages, and in particular overlooks Shepreth as a sustainable location for growth. Despite being classified as an Infill Village, Shepreth is a unique settlement, outside of the Green Belt, benefitting from one of the seven train stations within Greater Cambridge. The development of the land at Frog End, Shepreth (Site Reference: 40085) would provide considerable community benefits which wouldn't be achievable as part of a smaller development. Our representations also demonstrate the site's suitability for development, with reference to the site's assessment within the HELAA.

Full text:

As set out in our comments on Policy S/DS, we do not consider that the Plan contains sufficient small and medium site allocations, nor does it comply with paragraph 79 of the NPPF, which states that housing should be located where it will enhance or maintain the vitality of rural communities, to promote sustainable development in rural areas. It is clear that planning policies should identify opportunities for villages to grow and thrive, especially where this will support local services.

Paragraph E.9 of Appendix E to the Sustainability Appraisal states that ‘The Councils’ evidence shows that Greater Cambridge’s villages should play only a limited role in meeting future development needs to support delivery of a range of smaller sites and support the vitality of Greater Cambridge’s villages.’ As set out in our comments on the SA, we dispute that the SA provides an accurate and consistent assessment of the options, with many unjustified assumptions made in relation to villages which result in an artificially negative outcome.

Paragraphs E.24 and E.25 of Appendix E to the SA state that the better served villages have been subject to site specific sustainability appraisal, identified as sites at Rural Centres, Minor Rural Centres and Group Villages. It confirms that sites at other villages were not considered as reasonable options, as they would not provide sustainable locations to allocate development.

Whilst we do not dispute this to be the case for the majority of Infill villages, there are some Infill Villages which do benefit from a greater level of facilities and services, and public transport than others, such as Shepreth, which is also located outside of the Green Belt.

Shepreth is the only Infill Village which benefits from a train station and is the location of one of only seven stations within Greater Cambridge. In addition, the settlement already benefits from a number of other facilities, services and employment opportunities. Despite its status as an Infill Village, development within Shepreth would be consistent with the stated influences of the preferred spatial strategy, including reducing climate impacts through compact development located to connect homes and jobs where active and sustainable travel can be maximised, as well as making the best use of existing and committed key sustainable transport infrastructure. It would also support a rural community to thrive and sustain services.

The land at Frog End, Shepreth (Site Reference: 40085) has been promoted by Scott Properties throughout the emerging Plan process, and represents a unique opportunity to deliver a residential-led development outside of the Green Belt and within close proximity to the train station, of a quantum which would be capable of providing significant community benefits and open space. This would include employment use, incorporating smaller units at affordable rates to support Small and Medium Enterprises, as well as start-up businesses, sustainably located to maximise the connectivity the site provides through additional pedestrian and cycle links, as shown in the accompanying Framework Masterplan. The site also provides the opportunity to include further community benefits, working closely with the Parish to ensure those reflect the needs and aspirations of the local community. There is sufficient flexibility owing to the size of the site for this to include sports, leisure, recreational and/or retail uses.

A variety of housing including older persons’ accommodation, self-build properties, as well as key worker housing would also respond to local needs in an area with excellent accessibility into Cambridge.

The site was assessed within the HELAA (reference 40085), scoring a ‘red’ for suitability and ‘green’ for availability and achievability. This is due to the site scoring ‘red’ in relation to Townscape and Landscape, noting a TPO on site, with the assessment concluding that:
‘Development would significantly alter and harm the existing character of this small rural village and could effectively double the size of Shepreth. It would be an encroachment into the countryside, incongruous and an urbanisation of the rural landscape.’

We question how the conclusions have been arrived at, in the absence of any landscape studies forming part of the Plan’s evidence base. This is particularly considering many of the sites assessed within the HELAA are greenfield, edge of settlement locations, which do not receive the same commentary in relation to encroachment into the countryside and urbanisation of the rural landscape. The site is also not within the Green Belt, therefore we consider the site to have received an unduly negative assessment against this criterion.

Further, we would highlight that development of this quantum within Shepreth, which benefits from one of only seven train stations within Greater Cambridge, would enhance the sustainability of the settlement, capable of providing benefits in addition to housing which smaller scale development would be unable to provide. As previously referenced, this includes additional community benefits which could take the form of sports, leisure, recreation and/or retail, in addition to a broad range of housing and employment uses which would respond to many different needs within the area.

The site scored ‘amber’ against a number of criteria within the assessment, which we consider to be unjustified. In relation to flood risk, the site scores ‘amber’ despite being wholly within Flood Zone 1, and with negligible areas of low risk surface water flooding, which could be suitably addressed through a sustainable urban drainage system. As such, the site should receive a ‘green’ score against this criterion.

The site scores ‘amber’ in respect of Biodiversity and Geodiversity, with the assessment incorrectly stating that the site is within a SSSI. Part of the site’s south-western boundary is adjacent to the southern part of L-Moor, Shepreth SSSI, and the assessment notes that close consultation would be required with Natural England, including assessment of increased visitor pressure on the SSSI. The assessment also confirms that there are no priority habitats within the site, although notes the presence of hedges and wooded boundaries that are likely to have ecological value. The assessment confirms that development of the site may have a detrimental impact on a designated site, or those with a regional or local protection but that impact could be reasonably mitigated or compensated.

As shown in the Framework Masterplan accompanying these representations, a considerable landscape buffer would be included between the site’s boundary with the SSSI, and the proposed areas of built form. Further, additional sizeable areas of open space would be included, providing additional and alternative recreational opportunities to the SSSI, which could reduce recreational pressure on the protected areas. The Framework Masterplan also shows proposed diverted public rights of way around the edge of L-Moor Shepreth SSSI, resulting from discussions with the Wildlife Trust, who have confirmed that directing footpaths to the edge of the SSSI (currently through the centre) would be beneficial. Scott Properties are committed to working with the Wildlife Trust to protect and enhance the SSSI, an opportunity which is unique to the land at Frog End.

In addition, and in accordance with the provisions of the Environment Act 2021, the site could deliver a biodiversity net gain in excess of 10%, which would include the retention and enhancement of the boundary features. Owing to the significant biodiversity benefits that could be delivered on this site, owing in part to its location and size, it is considered that the site should be scored ‘green’.

The site is located within 750m of the train station, which provides access into the centre of Cambridge within 12 minutes. This equates to a walking time of approximately 10 minutes, or a cycle time of three minutes, and highlights how the suitability of the land at Frog End as a location for growth.

Shepreth is closely associated with the neighbouring villages of Foxton, Barrington, Meldreth and Melbourn, all of which provide additional services and facilities accessible on foot from the site via the existing public right of way network, or by cycling. Despite this, the site scores ‘amber’ in relation to Accessibility to Services and Facilities, which we consider is inaccurate and should be ‘green’.

As demonstrated within the accompanying Access Drawing, safe and suitable vehicular access into the site can be achieved from Frog End to the south. The HELAA recognises that the proposed site is acceptable in principle, subject to detailed design, yet scores ‘amber’ in relation to both Site Access and Transport and Roads. The accompanying Masterplan Concept Layout also demonstrates that multiple footpaths and cycle links could be provided through the site, providing recreational opportunities and providing sustainable transport options. As such, it is considered the site should score ‘green’ for these elements.

As shown within the accompanying Framework Masterplan, the site’s proximity to the railway has been factored into the design, with proposed open space and landscaping providing a considerable buffer between the proposed built form and the railway line. In addition, there are no issues on site in relation to light pollution or odour. As such, appropriate and effective mitigation can be provided on the site, therefore a score of ‘green’ is appropriate.

In light of the above, it is considered that Shepreth should be considered as a sustainable location for growth, in accordance with the aims of the Plan and the NPPF. The site represents a unique opportunity to deliver significant benefits through new housing, employment and community facilities, owing to its location and size, which would not be achievable on a smaller site or with a smaller quantum of development.