Gamlingay Neighbourhood Plan

Support

Representation ID: 56534

Received: 07/10/2021

Respondent: Natural England

Natural England does not have any specific comments on this Neighbourhood Plan submission.

Support

Representation ID: 56535

Received: 21/10/2021

Respondent: Cambridgeshire Local Access Forum

Cambridgeshire Local Access Forum (CLAF) was established through statutory provisions of Countryside and Rights of Way Act 2000
CLAF welcomes opportunity to provide input into Gamlingay Neighbourhood Plan and how it might be revised and improved to better reflect existing and potential future use of non-motorised transport network across Parish of Gamlingay.
We recognise that it's a very comprehensive plan, with a lot of concern for biodiversity, historical sites, and conservation. We are also pleased to see and support policies that aim to protect, enhance and develop the rights of way network providing a network of routes to promote walking, cycling and riding and to point out that circular routes, or routes that link with others, are particularly recommended.
The CLAF would be happy to discuss further our concerns and how we might help in achieving the plans ambition.

Support

Representation ID: 56536

Received: 29/10/2021

Respondent: National Grid

Agent: Avison Young

Proposed development sites crossed or in close proximity to National Grid assets:
An assessment has been carried out with respect to National Grid’s electricity and gas transmission assets which include high voltage electricity assets and high-pressure gas pipelines.
National Grid has identified that it has no record of such assets within the Neighbourhood Plan area.

Support

Representation ID: 56537

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

Objective 1 Housing Growth

Objective 1 recognises the need for appropriate housing growth in Gamlingay including the need for smaller and adaptable homes. This is supported.

Object

Representation ID: 56538

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

OBJECTIVE 4: COMMUNITY AMENITIES AND FACILITIES

The supporting text to Objective 4 advises that Policy GAM7 designates the former First School Playing Field as new Local Green Space with pedestrian access. It also advises that Policy GAM8 supports development of the former First School buildings for educational and community uses and safeguards the site for 10 years. Cambridgeshire County Council objects to Policies GAM7 and GAM8 under basic conditions A, D and E,
see representations submitted in respect of Policies GAM7 and GAM8 below. Thus, Cambridgeshire County Council also objects to the supporting text to Objective 4 under the same basic conditions.

Support

Representation ID: 56539

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

PARAGRAPHS 4.12 and 4.13

Paragraph 4.12 advises that the Bedfordshire Rural Communities Charity (BRCC) Housing Needs Survey Report (2018) indicates a particular demand for smaller 1-2-bedroom homes and bungalows in Gamlingay to meet the needs of single people requiring accommodation on their own, as well as older people seeking to downsize. Paragraph 4.13 recommends developers focus on less expensive, smaller, and adaptable 2 to 3- bedroom houses and bungalows. Cambridgeshire County Council supports the provision of smaller homes which could be explored as part of a mixed-use scheme at the former First School site.

Object

Representation ID: 56540

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

PARAGRAPH 4.60

Paragraph 4.60 advises that there is a shortfall of places for care of children during their early years in Gamlingay. It goes on to state that the existing former First School buildings would provide an ideal location for pre-school care. Policy GAM8 is proposing the reuse of the buildings on the former First School site for educational and community purposes where a need (e.g. for pre-school provision, a new doctors’ surgery or relocation of the Coop) can be met. Cambridgeshire County Council objects to Paragraph 4.60 under basic conditions A, D and E (see representations submitted in respect of Policy GAM8). Cambridgeshire County Council acknowledges its duty to provide pre-school places. However, while a detailed feasibility study of the site has not yet been carried out, based on experience in the area it is considered likely that a sole pre-school use would not be viable. Also, due to the size of the buildings multiple site occupants would be required. To produce an effective whole site solution, it is highly likely that a mixed use scheme will be required to support such facilities, however, this should not be restricted to education and community uses. Rather, greater flexibility should be provided to ensure a suitable viable scheme can be developed. This view was expressed by Cambridgeshire County Council as part of the Regulation 14 Consultation.

Support

Representation ID: 56541

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

PARAGRAPH 4.62
COMMENT
The former First School field is private land with no public access. Access to the former First School field is only granted through private agreements with Cambridgeshire County Council.

Object

Representation ID: 56542

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

GAM6 – COMMUNITY AMENITIES AND FACILITIES

Policy GAM6 states that the loss of amenities and facilities will be resisted unless it can be demonstrated that efforts have been made to secure their continued use and alternatives are provided. Cambridgeshire County Council objects to Policy GAM6 under basic
Condition A as the policy is not considered clear and unambiguous as required under Paragraph 16(d) of the NPPF and Paragraph 041 (Ref. 41-041-20140306) of the NPPG.
The policy does not define what falls within “amenities and facilities” for the purpose of the policy, or what an applicant is expected to demonstrate to show that “efforts have been made to secure their continued use”. Furthermore, it has not taken into account the
existing level of provision within the settlement. In line with the Local Plan, it is suggested that the wording be updated to “village services and facilities, including village pubs,shops, post offices, banks and building societies, community buildings and meeting
places, sports venues, cultural buildings, places of worship or health facilities, where such loss would cause an unacceptable reduction in the level of community or service provision in the locality”. This change in wording is also required to meet basic condition E (see below).

Policy GAM6 also does not meet basic condition E which requires general conformity with the strategic policies contained in the development plan. This includes Local Plan Policy SC/3: Protection of Village Services and Facilities which seeks to protect village services and facilities. However, as set out above, Policy GAM6 does not include the same definition of facilities and services as Policy SC/3. Furthermore, Policy SC/3 sets out clear guidance on what will be considered in determining the significance of the loss of a village service or facility:

a) “The established use of the premises and its existing and potential contribution to the social amenity of the local population;
b) The presence of other village services and facilities which provide an alternative, with convenient access by good local public transport services, or by cycling or
walking; and how these remaining uses will cope with displaced users; and any unacceptable impact of those alternative services or facilities;
c) The future economic viability of the use including the results of marketing of the premises for a minimum of 12 months at a realistic price and in appropriate cases
financial information.”
Neighbourhood Plan Policy GAM6 does not provide this clarity which is considered important for the application of the policy. Policy GAM6, therefore, does not conform with
Policy SC/3 of the Local Plan.

Object

Representation ID: 56543

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

GAM7 – DESIGNATION OF THE FORMER FIRST SCHOOL FIELD, GREEN END AS A LOCAL GREEN SPACE (TL 23582 52417) AND NEIGHBOURHOOD PLAN MAPS

Policy GAM7
Policy GAM7 designates the former First School Field as Local Green Space with pedestrian access. Cambridgeshire County Council objects to Policy GAM7 under basic Condition A as the policy is not realistic or deliverable. Paragraph 16(b) of the NPPF states that plans should “be prepared positively, in a way that is aspirational but deliverable”. This is repeated in Paragraph 005 (Ref. 41-005-20190509) of the NPPG which specifically covers neighbourhood plans. Paragraph 002 (Ref. 10-002-20190509) of the NPPG also
states that “it is the responsibility of plan makers in collaboration with the local community, developers and other stakeholders, to create realistic, deliverable policies”.

The former First School Field is private land with no public access (including no public rights of way across the land). Access is only granted through private agreements with Cambridgeshire County Council. Cambridgeshire County Council, as landowner, clearly
stated within their Regulation 14 consultation response that “access to the play fields will be granted, on permission only basis, to documented authorised users”. A Local Green Space designation does not confer any rights of public access over what exists at present
(NPPG, Paragraph 017, Ref. 37-017-20140306).
Therefore, there is no public access and the inclusion of “with pedestrian access” is neither realistic nor deliverable. Consequently, Policy GAM7 is not appropriate and does not meet basic Condition A.

Cambridgeshire County Council also object to the boundary of the proposed Local Green Space designation which includes the Scouts Hut and car park. Having regard to national policies and advice contained in guidance, the inclusion of the Scouts Hut and car parking within the proposed Local Green Space designation is considered inappropriate and does not meet basic Condition A.

The purpose of Local Green Space designations is to provide special protection for green areas of particular importance to local communities (NPPF, Paragraph 101; NPPG, Paragraph 005, Ref. 37-005-20140306). It is not considered that the Scouts Hut or associated car park fall within the definition of “green areas” to which Local Green Spaces designations apply.
While the definition of green areas includes “land where sports pavilions, boating lakes or structures such as war memorials are located, allotments, or urban spaces that provide a tranquil oasis” NPPG, (Paragraph 013, Ref. 37-013-20140306), the Scouts Hut and car park comprise built development that does not read as part of the former First School Field green area. Rather, the Scouts Hut and car park form part of the built-up area including the
former school. Therefore, they are considered to fall beyond the definition of a green area. Assets such as the Scouts Hut are covered under different areas of protection including through the existing Asset of Community Value (ACV) listing.

Neighbourhood Plan Maps
The following maps show the boundary to the proposed Local Green Space designation which includes the Scouts Hut and car park. This includes:
 Map 4: Landscape Setting
 Map 7: Key Policy Areas 1-12
 Map 9: Community Amenities and Facilities
 Map 10: Walking Cycling and Horse-Riding Routes
 Map 11: Gamlingay Wood – GAM12
As set out above, having regard to national policies and advice contained in guidance, the inclusion of the Scouts Hun and car parking within the proposed Local Green Space designation is considered inappropriate and does not meet basic Condition A.

Object

Representation ID: 56544

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

GAM8 – REUSE OF THE FORMER FIRST SCHOOL BUILDINGS, GREEN END (TL
23647 52413)

Policy GAM8 proposes the reuse of the former First School buildings and new buildings for educational and community uses (e.g Use Classes a, b, e, f, g). Cambridgeshire County Council objects to Policy GAM8 under basic conditions A, D and E.

Object

Representation ID: 56545

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

Policy GAM10 requires new residential and business units to contribute towards the provision and maintenance of new paths for the purpose of cycling, walking and horse riding between the village, hamlets, employment sites and neighbouring villages. It sets
out the level of contribution required. Appendix 3 sets out further information on developer contributions.

Cambridgeshire County Council objects to Policy GAM10 as it is not considered to meet basic Condition A. Paragraph 005 (Reference ID: 41-005-20190509) and Paragraph 001 (Reference ID: 10-001-20190509) of the NPPG advise respectively that: “Neighbourhood plans may also contain policies on the contributions expected from development, but these and any other requirements placed on development should accord with relevant strategic policies and not undermine the deliverability of the neighbourhood plan, local plan or spatial development strategy.”

“Plans should set out the contributions expected from development. This should include setting out the levels and types of affordable housing provision required, along with other infrastructure (such as that needed for education, health, transport, flood and water management, green and digital infrastructure). These policy requirements should be informed by evidence of infrastructure and affordable housing need, and a proportionate assessment of viability that takes into account all relevant policies, and local and national
standards, including the cost implications of the Community Infrastructure Levy (CIL) and
section 106…”

Insufficient evidence has been provided on how the proposed contributions relate to the strategic policies within the Local Plan or how they will impact the deliverability of the neighbourhood plan, local plan, or spatial development strategy. Furthermore, a
proportionate assessment of viability has not been provided. The lack of evidence also conflicts with Paragraph 31 of the NPPF and Paragraph 041 (Ref. 41-041-20140306) of the NPPG.

The policy is also ambiguous as the term “business developments” has not been defined so it is not clear what it is intended to include. Paragraph 16(d) of the NPPF and Paragraph 041 (Ref. 41-041-20140306) of the NPPG require policies be clear and unambiguous, so that it is obvious how the decision maker should apply them.
It should be noted that the former First School Playing Field was not identified as recreation space within the Council’s Recreation and Open Space Study (July 2013) nor within the Services and Facilities Study (March 2014).

Object

Representation ID: 56546

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

GAM11 – LANDSCAPE AND NATURAL ENVIRONMENT

Policy GAM11 advises that green spaces within developments should be consolidated to create a network of publicly accessible formal and informal green spaces – green infrastructures – for sport and recreation. Cambridgeshire County Council objects to Policy
GAM11 on the grounds that it is not deliverable (as required under Paragraph 16(b) of the NPPF) as not all green space within developments will necessarily be publicly accessible. Therefore, in its current wording the policy does not meet basic condition A.

It is suggested that the words “public open” be inserted at the start of the sentence so that it reads:
“Public open green space within developments should be consolidated to create a network of publicly accessible formal and informal green spaces – green infrastructures – for sport and recreation.”

Support

Representation ID: 56547

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

APPENDIX 2: GAMLINGAY’S GREEN INFRASTRUCTURE
COMMENTS
Appendix 2 identifies sites of sport, recreation and amenity value where residents can come together both informally and where community events are held. The Gamlingay First School playing fields, Green End (0.8 ha) (Asset of Community Value-ACV) is included within the list.
The former First School Playing Field is private land with no public access (including no public rights of way across the land). Access is only granted through private agreements with Cambridgeshire County Council. While the land was previously used for sports and recreation associated with the school use, the school use has now ceased owing to the relocation of the school.

Support

Representation ID: 56548

Received: 19/11/2021

Respondent: Cambridgeshire County Council

Agent: Carter Jonas

GENERAL
COMMENTS
Reference to the NPPF needs to be updated to the 2021 version.

The conservation area boundary does not exactly follow that drawn on the Local Plan Policy Map for Gamlingay.

Support

Representation ID: 56549

Received: 20/11/2021

Respondent: Mr Simon Fisher

Comment
My comment is specifically about the community gym, currently closed, but cited at Gamlingay Village Primary. We cannot consider this a long term site for the gym and would like to understand if there can be a mid/long term plan to have a longstanding and secure site for this community facility?
Perhaps as part the Old First School development plans (as referenced in GAM8 (4.69))? Or is there another site that could be identified over time?

Support

Representation ID: 56550

Received: 20/11/2021

Respondent: Mr Robert Petch

Comment
The Gamlingay community gym, currently closed but hopefully reopening as a non-profit charity in January 2022, is in a building that is part of Gamlingay Village Primary. The long-term future of the gym at this location is uncertain beyond 2024.
The gym is important to people in the village for their physical and mental health, it is essential for the future of the gym to be assured with an alternative location in the village included in the plan. Gamlingay needs this facility for the majority of gym users, many on doctor referral, who can’t travel to the alternatives.

Object

Representation ID: 56551

Received: 21/11/2021

Respondent: Ms Colleen Blyth

The plan appears too rigid with regard to currently privately owned open space, which may be gifted to the people of Gamlingay, for the benefit of the village.
It doesn’t allow any opportunity for such land to be gifted, assuming it will be green space, despite private land potentially being sold to developers for unpalatable mass housing in future, against affected residents’ wishes. A gift in perpetuity to the village would prevent this, and help maintain the character of the village.
The plan ignores the opportunity and potential for such gifts.

Support

Representation ID: 56562

Received: 23/11/2021

Respondent: Mr Gordon Brooks

Gamlingay Green

Proposing an additional area for recreational purposes.

Object

Representation ID: 56576

Received: 30/05/2023

Respondent: Wyboston Lakes Limited

Agent: Brown & Co Barfords

It is considered the plan as currently drafted does not meet the basic conditions of being compliant with national policies and advice, and elements are not in conformity with the adopted development plan. Overall, this will frustrate the delivery of some sustainable developments.
As explained in the accompanying representation letter the particular issues relate to
paragraphs 1.8, 2.13, 4.24, 4.25, 4.32, 4.35, 4.77, 4.81, 4.82, 4.95, 4.96 and Appendix 3.

Object

Representation ID: 56584

Received: 30/05/2023

Respondent: LJA Miers Executive Pension Fund

Agent: Brown & Co Barfords

GAM4

The local employment site in Church Street, as indicated in Policy GAM4, should be removed from the Neighbourhood Plan. The accompanying letter explains the lack of clarity in this policy, policy conflict with the Local Plan as well as highway safety and noise
issues related to this site.

Object

Representation ID: 56586

Received: 30/05/2023

Respondent: Merton College

Agent: Brown & Co Barfords

It is considered the plan as currently drafted does not meet the basic conditions of being compliant with national policies and advice, and elements are not in conformity with the adopted development plan. Overall, this will frustrate the delivery of potentially sustainable developments and revisions to address the above points are necessary.
As explained in the accompanying representation letter the particular issues relate to paragraphs 1.8, 2.13, 4.24, 4.32, 4.77, 4.81, 4.82, 4.95, 4.96, 4.97 and Appendix 3.

Support

Representation ID: 56589

Received: 23/11/2021

Respondent: O'Donovan Holdings Ltd

Agent: Iceni Projects Limited

Comment
We propose the site Land at Potton Road, Mill Hill, Gamlingay as a further housing allocation (for sustainable affordable housing). The Plan currently has no allocations for affordable housing, this site would provide one.The site is previously-developed land in an accessible location. Development on the site would meet the unmet need for affordable housing locally and also support local facilities.
The recent Housing Needs Survey (2021) supports the need for a further housing allocation, finding that
every year for the next 5-years a minimum of 27 households will be in affordable housing need, 135
households over 5-years.

Support

Representation ID: 56590

Received: 30/05/2023

Respondent: O'Donovan Holdings Ltd

Agent: Iceni Projects Limited

Objective 1 - We support this objective because there is a clear need for sustainable affordable homes, in
particular 1-2-bedroom dwellings and bungalows.

Objective 4 - We support this objective in line with the requirement in the NPPF (2021) at para. 79 for housing
in rural areas to be located where it will enhance or maintain the vitality of rural communities.

Policy GAM1 - We support this draft policy, specifically the requirement for housing development to “provide a
mix of homes, in particular one- or two-bedroom dwellings and bungalows.”

Policy GAM6 – We support the protection of community amenities and facilities.

Object

Representation ID: 56591

Received: 23/11/2021

Respondent: O'Donovan Holdings Ltd

Agent: Iceni Projects Limited

Objective 2 - This objective should include support for rural exception sites to meet a sustainable affordable
housing need, as long as they are well-designed.

Objective 5 - The objective therefore should not be to encourage more parking provision, but rather to provide
levels of parking appropriate to the site and circumstances.

Paragraphs 4.23, 4.31, text box on page 43 and Policies GAM3 and GAM9 - These state that the right place
for new homes is within the village boundary. We object to this because there is no reference to rural exception
sites. These are permitted according to South Cambridgeshire Local Plan Policy H/11, so the text should be amended to reflect this.

Object

Representation ID: 56592

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Policies Map and Maps

Concerns about clarity of maps.

Support

Representation ID: 56593

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Map 1
Map 1 shows the neighbourhood area for Gamlingay – we would recommend using a stronger map base that enable readers to find key information. In this instance, because land west of the parish boundary is in Bedfordshire, it might help if parish and district names and the district boundary were illustrated, and the boundaries clearly shown.
A Neighbourhood Plan must be clear about the area that it covers.

Support

Representation ID: 56594

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Map 4

Map 4 shows landscape settings. It would help the future user of the Plan if there were a greater distinction between the green shadings shown on the map. They look somewhat the same. The key refers to ‘examples of good design’ but does not name these two places or provide any supporting details for why these are examples of good design.

Support

Representation ID: 56595

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Map 6
Map 6 showing Village Amenities –This map is attempting to show much information across the whole parish. By having a parish wide map this has resulted in the village centre, where many of the facilities are located, at a very small scale and it is not possible to define the exact location of those facilities.

Object

Representation ID: 56596

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Chapter 3 - Our vision
With regards to Objective 1, it is not clear how the reference to ‘high environmental standards’ is defined. For the sake of clarity, it may be better for the Neighbourhood Plan to promote new development that seeks to ‘exceed the baseline policy requirements for sustainability set out in section 4 of the Local Plan, supporting the transition to net zero carbon and the move away from fossil fuels.’