Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 59226

Received: 13/12/2021

Respondent: Scott Properties

Representation Summary:

Land to the west of South Street, Comberton (HELAA Site 40310)

We do not consider that sufficient growth has been directed to village locations. Comberton is a Minor Rural Centre; one of the most sustainable settlements within Greater Cambridge and one which should be considered as a location for growth. Scott Properties has promoted the land to the west of South Street, Comberton (Site Reference: 40310) for residential development through the emerging Plan process. We disagree with the conclusions of site's assessment within the HELAA, in that it represents a suitable and sustainable site for allocation, not least due to its accessibility to services, facilities and transport links within Comberton.

Full text:

As set out in our comments on the SA, we consider that the spatial distribution fails to direct sufficient growth to villages, and therefore does not fit with the contention that this was strongly influenced by the desire to support rural communities to thrive and sustain services.

Comberton is a Minor Rural Centre, recognised within the South Cambridgeshire Local Plan as having a greater level of services, facilities and employment than most other villages in South Cambridgeshire.

Scott Properties has promoted the land to the west of South Street, Comberton (Site Reference: 40310) through the emerging Plan process for residential development. The site received a ‘red’ score for suitability, and a ‘green’ score for both availability and achievability.

The site scores ‘red’ against Site Access, with the assessment concluding that there is no possibility of creating a safe access. This conclusion is disputed. As shown within the Masterplan Concept Layout accompanying the submission, Scott Properties has identified a number of potential access points into the site, which would provide safe and suitable access onto a public highway. As such, we consider this should be amended to ‘amber’ to reflect the situation.

It also scores ‘red’ against Strategic Highways Impact. We would reiterate our earlier comments on this part of the site assessment, which draws arbitrary zones that assume all traffic will use the specified junction. Further, Comberton is also located within the north-western corner of Zone 8, within close proximity to Zones 9 and 10 which are noted as having capacity for growth. Additionally, we note from Appendix 2 to the HELAA that a ‘red’ score does not rule out sites at this stage, as development proposals within these zones will need to demonstrate no net increase in vehicle trips on the strategic road network. A red score, regardless of whether this is possible, has acted to rule out sites from consideration for allocation by scoring them ‘red’ for suitability. As such, we consider the sites in the zones identified as having no capacity for growth should be scored ‘amber’ to reflect that this should not rule out development at this stage.

In relation to Flood Risk, the site is located wholly within Flood Zone 1, with only a small proportion of the site area at risk from surface water flooding. Given the limited extent of the area affected, and the ability to effectively mitigate any risk through a sustainable urban drainage strategy, we consider this assessment should be amended to ‘green’.

The site scores ‘amber’ in relation to Landscape and Townscape. We question why views from neighbouring properties into the site warrants a score of ‘amber’, particularly when this is the case for the majority of sites close to a settlement edge and has not been noted in respect of any other site regardless of its proximity to other properties. The inclusion of landscape buffers is also provided as a mitigation measure, although we question what evidence exists to support the requirement for a 15m buffer between the site and existing properties, particularly when development of the site would require minimum back-to-back distances and good design principles to be observed. Given there would be a design solution to mitigate any potential concerns around the site’s relationship to surrounding uses, we consider that the site should be scored ‘green’.

In relation to Biodiversity and Geodiversity, the site scores ‘amber’, noting the requirement for an assessment of increased visitor pressure on the Eversden and Wimpole Woods SAC, which is a considerable distance from the site. The assessment notes that the site may have a detrimental impact on a designated site, but any impact could be reasonably mitigated or compensated. As such, we are unclear why the assessment does not score ‘green’ given there is a satisfactory solution should any mitigation be required (which the assessment assumes but is not confirmed).

The site scores ‘amber’ in relation to Historic Environment, being located within 100m of both a Listed Asset and a Conservation Area. It is clear from the Village Inset Map for Comberton that the main Conservation Area is physically separated from the site by considerable intervening built form.
The secondary Conservation Area, located to the east of South Street and to the south-east of the site is also separated from the site by intervening vegetation, which visually separates the site from this area. The closest listed building is also adjacent to South Street to the east of the site, and is separated from the site by built form and a considerable landscaping which screens the asset from the site.

As such, we question how the site could have any impact on either, and the assessment should be amended to ‘green’ to more accurately reflect the situation.

We would highlight the site’s ‘green’ score in relation to Accessibility to Facilities and Services. Development of the site would fully accord with the Council’s objectives to located development where climate change could be mitigated, close to existing facilities, services and public transport.

The Green Belt assessment concluded the harm rating to be ‘moderate’ for the site (parcel CO10), one of the lower scoring parcels surrounding the settlement.