Fulbourn Neighbourhood Plan - submission version
Representation ID: 59369
Respondent: Cambridgeshire & Peterborough NHS Foundation Trust
Delete paragraph 2 of Policy FUL /01 since it duplicates other policy designations having regard to the Neighbourhood Plan putting forward the concept of an Important Visual Gap. The Cambridge Green Belt as a designation already fulfills distinct purposes having regard to guidance with National Planning Policy Framework
Delete paragraph 2 of Policy FUL /01 since the reference to an Important Visual Gap designation duplicates other policy designations including the Green Belt. Reference to an Important Visual Gap policy and reference to it elsewhere in the document should be removed including Figure 8
Representations on behalf of Cambridgeshire & Peterborough NHS Foundation Trust to the Submitted version of the Fulbourn Neighbourhood Plan
Policy FUL/01 - "Protecting the Distinctiveness and Landscape Setting of Fulbourn"
Cambridgeshire & Peterborough NHS Foundation Trust are the freehold landowners of land at Fulbourn Hospital. This is the site currently occupied by a number of healthcare services and located to the west of Capital Park (referred to as the “former Fulbourn Hospital site”) within the Neighbourhood Plan)
Whilst supporting the publication of a draft Neighbourhood Plan, the Trust is needing to ensure that the policies and proposals within the document do not, as far as reasonably possible, hinder the delivery of vitally important healthcare services. The Trust at its heart must prioritise healthcare provision, an aspiration and objective brought more sharply into focus during the global pandemic.
Policy FUL/01 within the Draft Neighbourhood Plan relates to the setting of the village and its separation from the City. The policy contains six paragraphs of policy wording which seek to protect the distinctiveness and the landscape setting of the village.
The first paragraph is of a generic nature to protect and enhance the setting and special character of Fulbourn by ensuring that all development proposals should not have an adverse effect on the rural character and openness of the landscape setting. We would support such a statement having regard to planning policies which are positively written and which should not advocate poor or inappropriate development as a matter of course.
The second paragraph within the policy states that development will not be permitted which would encroach on or reduce the current dominant green aspect of the “Important Visual Gap between Fulbourn and the boundary of the urban area of Cambridge and neighbouring villages”. The Neighbourhood Plan has introduced this new “Important Visual Gap” policy approach which would appear to be a strategic policy which duplicates a number of other policies within national or local context.
The area that is the subject of the Important Visual Gap is shown in Figure 8 of the Neighbourhood Plan and correlates with an area of land already designated as Green Belt whose purposes are set out within national planning policy guidance in the NPPF at paragraph 138.
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.”
These Green Belt purposes in our view duplicate the Important Visual Gap proposal put forward in the Neighbourhood Plan and simply places another policy on top of an existing policy. Indeed, looking at the Important Visual Gap approach in more detail, it is directed to development which would “encroach on or reduce the current dominant green aspect of the Important Visual Gap” within that area. It suggests that development which would not encroach upon or reduce the green aspect would not be relevant in the context of this policy wording given this is the only reference to the Important Visual Gap in terms of policy wording.
In this context, the Trust has already made representations to the Greater Cambridge Local Plan Consultation documents to remove the current built up area of Fulbourn Hospital from the Green Belt on the basis of the nature and character of the built up form in that location does not fulfil Green Belt purposes. ( see enclosed) This is similarly the case with the intention of including Fulbourn Hospital within an Important Visual Gap policy which already duplicates other policies. Accordingly, the Trust do not support Policy FUL/01 having regard to the duplicating nature of the policy and the layer of further policy designations within the area.
It is the case that under the current regime of planning policies within the development plan , the Trust must on every occasion must make the case for Very Special Circumstances for building within the Green Belt. It is the Trust’s view that land which falls in the northern part of the Fulbourn Hospital site is of a character that it is no longer fulfilling a Green Belt function given its built form including land that has the benefit of planning permission (eg. the new Resource Centre granted planning permission in April 2021 (20/02887/FUL). Indeed in the current climate of significant pressure upon healthcare services and their effective and efficient delivery, it is vital that such planning constraints do not jeopardise forward looking plans to consolidate such critical and important facilities on the Fulbourn Hospital site .
Turning to Paragraphs 4 and 5 within Policy FUL/01, the text lists a number of identified “Locally Important Views” in Figure 9 of the Plan and then states development will not be permitted where it would adversely affect the setting of those views or the loss of woodland and openness. In the cases where development could proceed within those viewpoints and where it would not affect the views or the woodland or open areas (notwithstanding any other policy designations) then proposals would presumably not be considered relevant in the context of this part of the Policy.
As stated above it is the Trust’s view to establish a planning framework where it able to deliver new and improved healthcare services based around the existing built up area of the hospital. In the circumstances where such development would be consolidating the existing built form we would consider it would safeguard such viewpoints.