Foxton Neighbourhood Plan -Submission version 2020

Good afternoon, thank you for the opportunity to comment on the above document – in regards to Policy we would wish to mention:

NPPF s.12 Para 127 which states: -

Developments should create places that are safe, inclusive and accessible and which promote health and well-being, with a high standard of amenity for existing and future users and where crime and disorder, and the fear of crime, do not undermine the quality of life or community cohesion and resilience.

In regards to design and layout regarding new commercial and residential development we would wish to make the following comment:

Crime prevention should be considered as an integral part of any initial design for a proposed development. It should incorporate the principles of ‘Secured by Design’. In particular to demonstrate how their development proposal has addressed the following issues, in order to design out crime to reduce the opportunities for crime:

• Natural Surveillance of public and semi-private spaces, in particular, entrances to a development, paths, play areas, open spaces and car parks.
• Defensible space and the clear definition, differentiation and robust separation of public, private and semi-private space, so that all the spaces are clearly defined and adequately protected in terms of their use and ownership.
• Consideration for some lighting, in particular shared parking courts and footpaths.
• Design and layout of pedestrian, cycle and vehicle routes into and within the site, including how these integrate with existing patterns in the village.
• Landscaping and planting, in particular, potential hiding places and dark or secluded areas should not be created.

In practice this means that Secured by Design status for new housing developments and commercial premises including railway stations and other travel hubs – this can be achieved through careful design and the use of a limited number of through routes, so that they are well used, effectively lit and overlooked, thereby creating a safe and secure atmosphere. Developers should, at an early stage, seek advice from the Police Designing out Crime Officers at Cambridgeshire Police Headquarters on designing out crime.

Policy FOX/5 (p44) refers to Sensitive Edges, these are shown on Fig 15 (p48) in blue hatching.
Policy FOX/6 (p47) refers to maintaining and enhancing views in and out of the parish.
These Sensitive Edges surround most of the village of Foxton, but do not include an area to the East of Station Road, or behind the Grade 2 listed Threshing Barn.
I would like to suggest the Sensitive Edges be extended to include behind the Threshing Barn as well as to the East of Station Road.

Thank you for your consultation on the above Neighbourhood Plan received by Natural England on 11 January 2021.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England is a statutory consultee in neighbourhood planning and must be consulted on draft neighbourhood development plans by the Parish/Town Councils or Neighbourhood Forums where they consider our interests would be affected by the proposals made.

Natural England welcomes that the Foxton Neighbourhood Plan seeks to protect and enhance local biodiversity in accordance with Natural Cambridgeshire’s ‘Doubling Nature’ target and the Cambridgeshire Green Infrastructure Strategy. We also support recognition of the importance of maintaining and enhancing accessible green infrastructure to meet people’s needs. The safeguarding of land through Policy FOX/14, to create an extensive ecologically enhanced area of chalk grassland between Foxton Woods and the village, is welcomed.

Since submission of the initial draft Foxton Neighbourhood Plan Natural England has introduced the Cambridgeshire Sites of Special Scientific Interest (SSSI) Recreational Pressure Impact Risk Zone (IRZ). This flags areas where new housing development poses a potential risk of damage or disturbance to accessible SSSIs due to increased levels of visitor pressure. Neighbourhood Plan policies FOX/9 and FOX/20 fall within the IRZ hence new housing development, in combination with others in the local area, has the potential to adversely impact sites such as L-Moor Shepreth SSSI and Fowlmere Watercress Beds SSSI through additional recreational pressure. Development should address this and mitigate any adverse impact, for example through the delivery / contribution towards delivery of alternative new or enhanced accessible greenspace and/or through a financial contribution towards enhanced management of the designated sites affected. Our advice is that policies FOX/9 and FOX/20 should seek to secure this, for example through a requirement for a contribution towards the implementation of the area of proposed chalk grassland / accessible greenspace on land safeguarded through Policy FOX/14.

For any further consultations on your plan, please contact: consultations@naturalengland.org.uk.

Amend policies FOX/9 and FOX/20 to seek mitigation.

Thank you for your consultation on the above Neighbourhood Plan received by Natural England on 11 January 2021.

Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.

Natural England is a statutory consultee in neighbourhood planning and must be consulted on draft neighbourhood development plans by the Parish/Town Councils or Neighbourhood Forums where they consider our interests would be affected by the proposals made.

Natural England welcomes that the Foxton Neighbourhood Plan seeks to protect and enhance local biodiversity in accordance with Natural Cambridgeshire’s ‘Doubling Nature’ target and the Cambridgeshire Green Infrastructure Strategy. We also support recognition of the importance of maintaining and enhancing accessible green infrastructure to meet people’s needs. The safeguarding of land through Policy FOX/14, to create an extensive ecologically enhanced area of chalk grassland between Foxton Woods and the village, is welcomed.

Since submission of the initial draft Foxton Neighbourhood Plan Natural England has introduced the Cambridgeshire Sites of Special Scientific Interest (SSSI) Recreational Pressure Impact Risk Zone (IRZ). This flags areas where new housing development poses a potential risk of damage or disturbance to accessible SSSIs due to increased levels of visitor pressure. Neighbourhood Plan policies FOX/9 and FOX/20 fall within the IRZ hence new housing development, in combination with others in the local area, has the potential to adversely impact sites such as L-Moor Shepreth SSSI and Fowlmere Watercress Beds SSSI through additional recreational pressure. Development should address this and mitigate any adverse impact, for example through the delivery / contribution towards delivery of alternative new or enhanced accessible greenspace and/or through a financial contribution towards enhanced management of the designated sites affected. Our advice is that policies FOX/9 and FOX/20 should seek to secure this, for example through a requirement for a contribution towards the implementation of the area of proposed chalk grassland / accessible greenspace on land safeguarded through Policy FOX/14.

For any further consultations on your plan, please contact: consultations@naturalengland.org.uk.

Thank you for your consultation which we received on the 10th March 2020.
We have reviewed the Foxton Neighbourhood Plan 2020 to 2031 and have the following comments to make:
We note that the Neighbourhood Plan does not include any policies relating to flood risk or surface water drainage in Foxton. We advise that such policies are included and would like to draw your attention to the Cambridgeshire Flood and Water Supplementary Planning Document which should assist in the development of the Neighbourhood Plan.

Thank you for your consultation.

Environment Agency position.
Due to resource pressures we are no longer able to provide you with comprehensive bespoke advice on neighbourhood plans.

We have no further comment on this proposal.

Foxton Neighbourhood Plan Regulation 16 Consultation
March 2020
Representations on behalf of National Grid
National Grid has appointed Avison Young to review and respond to Neighbourhood Plan consultations on its behalf. We are instructed by our client to submit the following representation with regard to the current consultation on the above document.
About National Grid
National Grid Electricity Transmission plc (NGET) owns and maintains the electricity transmission system in England and Wales. The energy is then distributed to the electricity distribution network operators, so it can reach homes and businesses.
National Grid Gas plc (NGG) owns and operates the high-pressure gas transmission system across the UK. In the UK, gas leaves the transmission system and enters the UK’s four gas distribution networks where pressure is reduced for public use.
National Grid Ventures (NGV) is separate from National Grid’s core regulated businesses. NGV develop, operate and invest in energy projects, technologies, and partnerships to help accelerate the development of a clean energy future for consumers across the UK, Europe and the United States.
National Grid assets within the Neighbourhood area:
Following a review of the above document we have identified the following National Grid assets as falling within the Neighbourhood area boundary:
Gas Transmission
Asset Description
Gas Transmission Pipeline, route: HUNTINGDON TO CAMBRIDGE
A plan showing details of National Grid’s assets is attached to this letter. Please note that this plan is illustrative only.
National Grid also provides information in relation to its assets at the website below.
• www2.nationalgrid.com/uk/services/land-and-development/planning-authority/shape-files/
Please see attached information outlining guidance on development close to National Grid infrastructure.
Distribution Networks
Information regarding the electricity distribution network is available at the website below:
www.energynetworks.org.uk
Information regarding the gas distribution network is available by contacting:
plantprotection@cadentgas.com
Further Advice
Please remember to consult National Grid on any Neighbourhood Plan Documents or site-specific proposals that could affect our assets.

Thank you for inviting Historic England to comment on the Regulation 16 Submission version of this Neighbourhood Plan.
We welcome the production of this neighbourhood plan, but do not wish to provide detailed comments at this time. We would refer you to any previous comments submitted at Regulation 14 stage, and for any further information to our detailed advice on successfully incorporating historic environment considerations into your neighbourhood plan, which can be found here: https://historicengland.org.uk/advice/planning/plan-making/improve-your-neighbourhood/
I would be grateful if you would notify me if and when the Neighbourhood Plan is made by the district council. To avoid any doubt, this letter does not reflect our obligation to provide further advice on or, potentially, object to specific proposals which may subsequently arise as a result of the proposed NP, where we consider these would have an adverse effect on the historic environment.

Amend 10.11 to clarify that the Cambridge South station proposal is not a GCP project.

Amend wording of FOX/19

Suggested changes to Section 8 of the Plan

Thank you for consulting Sport England on the above neighbourhood plan.

Government planning policy, within the National Planning Policy Framework (NPPF), identifies how the planning system can play an important role in facilitating social interaction and creating healthy, inclusive communities. Encouraging communities to become more physically active through walking, cycling, informal recreation and formal sport plays an important part in this process. Providing enough sports facilities of the right quality and type in the right places is vital to achieving this aim. This means that positive planning for sport, protection from the unnecessary loss of sports facilities, along with an integrated approach to providing new housing and employment land with community facilities is important.

It is essential therefore that the neighbourhood plan reflects and complies with national planning policy for sport as set out in the NPPF with particular reference to Pars 96 and 97. It is also important to be aware of Sport England’s statutory consultee role in protecting playing fields and the presumption against the loss of playing field land. Sport England’s playing fields policy is set out in our Playing Fields Policy and Guidance document.
https://www.sportengland.org/how-we-can-help/facilities-and-planning/planning-for-sport#playing_fields_policy

Sport England provides guidance on developing planning policy for sport and further information can be found via the link below. Vital to the development and implementation of planning policy is the evidence base on which it is founded.
https://www.sportengland.org/how-we-can-help/facilities-and-planning/planning-for-sport#planning_applications

Sport England works with local authorities to ensure their Local Plan is underpinned by robust and up to date evidence. In line with Par 97 of the NPPF, this takes the form of assessments of need and strategies for indoor and outdoor sports facilities. A neighbourhood planning body should look to see if the relevant local authority has prepared a playing pitch strategy or other indoor/outdoor sports facility strategy. If it has then this could provide useful evidence for the neighbourhood plan and save the neighbourhood planning body time and resources gathering their own evidence. It is important that a neighbourhood plan reflects the recommendations and actions set out in any such strategies, including those which may specifically relate to the neighbourhood area, and that any local investment opportunities, such as the Community Infrastructure Levy, are utilised to support their delivery.

Where such evidence does not already exist then relevant planning policies in a neighbourhood plan should be based on a proportionate assessment of the need for sporting provision in its area. Developed in consultation with the local sporting and wider community any assessment should be used to provide key recommendations and deliverable actions. These should set out what provision is required to ensure the current and future needs of the community for sport can be met and, in turn, be able to support the development and implementation of planning policies. Sport England’s guidance on assessing needs may help with such work.
http://www.sportengland.org/planningtoolsandguidance

If new or improved sports facilities are proposed Sport England recommend you ensure they are fit for purpose and designed in accordance with our design guidance notes.
http://www.sportengland.org/facilities-planning/tools-guidance/design-and-cost-guidance/

Any new housing developments will generate additional demand for sport. If existing sports facilities do not have the capacity to absorb the additional demand, then planning policies should look to ensure that new sports facilities, or improvements to existing sports facilities, are secured and delivered. Proposed actions to meet the demand should accord with any approved local plan or neighbourhood plan policy for social infrastructure, along with priorities resulting from any assessment of need, or set out in any playing pitch or other indoor and/or outdoor sports facility strategy that the local authority has in place.

In line with the Government’s NPPF (including Section 8) and its Planning Practice Guidance (Health and wellbeing section), links below, consideration should also be given to how any new development, especially for new housing, will provide opportunities for people to lead healthy lifestyles and create healthy communities. Sport England’s Active Design guidance can be used to help with this when developing planning policies and developing or assessing individual proposals.

Active Design, which includes a model planning policy, provides ten principles to help ensure the design and layout of development encourages and promotes participation in sport and physical activity. The guidance, and its accompanying checklist, could also be used at the evidence gathering stage of developing a neighbourhood plan to help undertake an assessment of how the design and layout of the area currently enables people to lead active lifestyles and what could be improved.

NPPF Section 8: https://www.gov.uk/guidance/national-planning-policy-framework/8-promoting-healthy-communities

PPG Health and wellbeing section: https://www.gov.uk/guidance/health-and-wellbeing

Sport England’s Active Design Guidance: https://www.sportengland.org/activedesign

Thank you for inviting the Forestry Commission to respond to the consultation on the Foxton Neighbourhood Plan. Unfortunately we do not have the resources to respond to individual plans but we have some key points to make relevant to all neighbourhood plans.
Forestry Commission and Neighbourhood Planning
Existing trees in your community
The Forestry Commission would like to encourage communities to review the trees and woodlands in their neighbourhood and consider whether they are sufficiently diverse in age and species to prove resilient in the face of tree pests and diseases or climate change. For example, if you have a high proportion of Ash, you are likely to see the majority suffering from Ash Dieback. Some communities are proactively planting different species straight away, to mitigate the effect of losing the Ash; you can find out more here. Alternatively, if you have a high proportion of Beech, you may find they suffer particularly from drought or flood stress as the climate becomes more extreme. There are resources available to help you get ideas for other species you can plant to diversify your tree stock and make it more resilient.
Ancient Woodland
If you have ancient woodland within or adjacent to your boundary it is important that it is considered within your plan. Ancient woodlands are irreplaceable, they have great value because they have a long history of woodland cover, with many features remaining undisturbed. This applies equally to Ancient Semi Natural Woodland (ASNW) and Plantations on Ancient Woodland Sites (PAWS). It is Government policy to refuse development that will result in the loss or deterioration of irreplaceable habitats including ancient woodland, unless “there are wholly exceptional reasons and a suitable compensation strategy exists” (National Planning Policy Framework paragraph 175).
The Forestry Commission has prepared joint standing advice with Natural England on ancient woodland and veteran trees. This advice is a material consideration for planning decisions across England and can also be a useful starting point for policy considerations.
The Standing Advice explains the definition of ancient woodland, its importance, ways to identify it and the policies that relevant to it. It provides advice on how to protect ancient woodland when dealing with planning applications that may affect ancient woodland. It also considers ancient wood-pasture and veteran trees. It will provides links to Natural England’s Ancient Woodland Inventory and assessment guides as well as other tools to assist you in assessing potential impacts.

Deforestation

The overarching policy for the sustainable management of forests, woodland and trees in England is a presumption against deforestation.

Woodland Creation

The UK is committed in law to net zero emissions by 2050. Tree planting is recognised as contributing to efforts to tackle the biodiversity and climate emergencies we are currently facing. Neighbourhood plans are a useful mechanism for promoting tree planting close to people so that the cultural and health benefits of trees can be enjoyed alongside their broader environmental benefits. Any planting considered by the plan should require healthy resilient tree stock to minimise the risk of pests and diseases and maximise its climate change resilience, a robust management plan should also be put in place.

I write on behalf of the Greater Cambridge Partnership (GCP) in connection with the above consultation, which has been restarted following it being paused last year due to COVID.

Prior to the pausing of the consultation, the GCP submitted representations to the draft neighbourhood plan – see attached for reference.

Since submitting the original representations, the GCP has been working up the proposed Travel Hub in the background and considered it necessary to submit a short update – see attached - which we trust will be taking into consideration alongside the original representations.

I write on behalf of the Greater Cambridge Partnership (GCP) in connection with the above consultation, which has been restarted following it being paused last year due to COVID.

Prior to the pausing of the consultation, the GCP submitted representations to the draft neighbourhood plan – see attached for reference.

Since submitting the original representations, the GCP has been working up the proposed Travel Hub in the background and considered it necessary to submit a short update – see attached - which we trust will be taking into consideration alongside the original representations.

Thank you for the work undertaken by the PC in the preparation of the revised Neighbourhood Plan. I am grateful to the PC for taking on board the comments of residents.

The Consultation Statement refers at appendix 9 (p.56) to a discussion concerning the sensitive urban edge and the possibility of extending it 'to include boundaries behind Church View and barn to west of footpath'.


The document records the PC having '[d]iscussed and agreed to extend', and refers to figs 15 and 30B of the revised plan.


However, figs 15 and 30B show that the boundary behind the grade 2 listed barn to the west of the footpath is not classified as sensitive edge. This may be an oversight, but either way I would urge the PC to revisit this issue.

It seems to me that the boundary in question, abutting open fields, should be classified as part of the village's sensitive edge, as should the boundary that runs behind the houses along Station Road. As far as possible, the edge of the village abutting open fields should be protected

If however the PC has considered this issue and decided that there is a rational basis for not continuing the sensitive edge along the boundary west of Church View, I would be grateful if the PC's reasoning could be explained in the revised plan.

Many thanks for considering this submission, and for your continuing efforts on behalf of our community.