Gamlingay Neighbourhood Plan

Support

Representation ID: 56597

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

NPPF
In general, there is nothing in the Plan to acknowledge whether it has been prepared in the context of the 2019 NPPF, which would have been current at the time of the Regulation 14 consultation, or the 2021 NPPF which is now current.

Object

Representation ID: 56598

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Housing Growth

Concerns about the housing needs survey that accompanies the Plan.

Concerns about wording on housing exception sites

Object

Representation ID: 56599

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

GAM1 New Buildings

Policy Bullet 1 - This policy could be more specific about meeting the local housing need for smaller dwellings for youngsters and for downsizing.

Policy Bullet 2 - The Policy is seeking to set standards of insulation that are restricted by the 2015 Ministerial Statement that states that neighbourhood plans should not set local standards. Energy Performance Certificate (EPC) ratings A is regulated by building regulations not planning policy. By including this requirement, the policy would not be taking account of national planning policy and likely to be removed by an examiner.

Policy Bullet 3 - Whilst noting that Objective 1 of your Plan refers to homes being adaptable across the lifetime of the building and that this aim had been included in the 3rd bullet of Policy GAM1 there needs to evidence for this. It is not clear that a need been established that more homes than the 5% identified in Policy H/9: Housing Mix in the Local Plan needing to meet M4(2) and/or M4(3) of the optional requirements in the Building Regulations been identified for the area.

Policy Bullet 3 – The reasoning for the requirement for a new development to be fitted with an electric charging point is not set out in the supporting text. Also, there is no information set out as to how this would be applied for flatted developments

Policy Final paragraph The Government introduced national technical standards for housing in 2015. A Written Ministerial Statement explains that neighbourhood plans should not set out any additional local technical standards or requirements relating to the construction, internal layout or performance of new dwellings. In the light of this Statement, we do not consider it appropriate to set the standards for dwellings in this paragraph, although a neighbourhood plan can set requirements for non-residential buildings.

Object

Representation ID: 56600

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

GAM2 Site allocation

The policy should state simply that the site at West Road is allocated for housing as identified on Map 7. It does not need to add that it will meet the housing needs requirement provided by SCDC as part of its duty set out in paragraph 67 of NPPF. This explanation should be within the supporting text for the policy. The policy is not referencing the correct paragraph in the latest published NPPF. It should be paragraph 67 rather than paragraph 65.

Paragraph 4.25 –There is a reference to the reserved matters planning application for Land South of West Road. It would be better to mention that, as of 21.10.2021, this reserved matters application (planning ref. S/3868/18/RM) has yet to be determined.

The explanation as to why this site-specific allocation policy has been included in the Plan is incorrect/ misleading. In this instance it is considered that the Parish Council should be allocating this site because the principle of development has been accepted and it safeguards the development should the permission lapse. We have previously suggested the following wording to explain the advantage of having a site allocation in the Plan:
“By allocating sites and meeting the identified housing requirement, the Neighbourhood Plan fully accords with the requirements of Paragraph 14 of the NPPF in meeting the identified housing requirement in full and therefore providing some certainty in determining proposals for new housing should the District Council not be able to demonstrate a five-years supply of housing sites in the near future.”

This policy is accompanied by Map 8 showing the proposed site layout for the West Road Site which is from the planning permission. There is no key or annotation to explain the layout or references to where the site is within the village for those who do not have local knowledge. It would benefit from annotations showing site features, access, connections and surrounding land uses.

The map would need to acknowledge a copyright.

Object

Representation ID: 56601

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

GAM3 Local Character

First bullet of the policy - The VDG identifies a number of architectural and spatial characteristics which are important to local character. The policy is being contradictory by stating in the first sentence that development will be supported where it follows the guidance in the VDG but then identifying only existing vernacular buildings as reference points for new design in the bullet point.

Second bullet point of policy - Protecting the unique structural layout of the village with the distinct gap between the main village and its hamlets is a key issue for the Plan. An inset map accompanying this policy annotated to show clearly the unique character of the parish with the main village and hamlets would have helped to clarify the purpose of the policy. Such a clear map is included within the VDG (Figure 6 page 9).

Second bullet point of policy - In the third sentence mention is made of preserving key views to and from the village and referring to both Maps 4 and 7. Only one map needs to be referenced in the policy and we would suggest Map 7.

These views also appear to be mentioned /protected by Policy GAM11. The views are listed in Appendix 2 and shown on the Key Policies areas Map 7. The last sentence of paragraph 4.32 states that the views are not just listed in Appendix 2 but illustrated which they are not. In neither policy GAM3 nor policy GAM11 is there a list of the views to be protected nor such a list in the supporting text. We consider without this information that this would be a difficult policy to implement successfully for developers drafting schemes and development management officers determining planning applications that may include proposals that impact views.

We are aware that additional assessment work was carried out following the Regulation 14 consultation and this has been submitted as an evidence document – Landscape and Visual Analysis (LVA) (July 2021). Most of the views listed in Appendix 2 of the Plan were identified in the VDG but the recent analysis identified two additional viewpoints, but no indication is given within the Plan as to which of the views these are. These are mentioned in the LVA as Key Views 6 and 7 but the Key View 7 Mill Bridge does not appear to have made it into the Plan as only 6 views are listed in Appendix 2. It is not clear whether View 7 would impact the Mill Hill employment Policy GAM5. It would help the future user of the plan if each view listed in Appendix 2 had a specific reference within a single policy and an inset map clearly showed each view. A brief description of each view could be included in the supporting text setting out its value. Such information is set out in the LVA. There should be a clearer link between the LVA and the policy protecting views.

Views appear to be to north and east of village. The policy protecting the hamlets is to the west and south which results in a cordon of protection around the village. We are concerned that this may not leave any room for future development. Developers could question the sustainability of the Plan if too much is protected.

Object

Representation ID: 56602

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Local Economy and employment

We welcome the inclusion of Map 5A which shows the existing business sites, but this does not clearly identify the specific employment sites mentioned in the two employment policies. This would help those future users of the Plan who do not have a local knowledge of the parish. Other features are also shown on this map which do not relate to employment which is confusing e.g., Gamlingay Wood Cordon.

There are two policies regarding employment - GAM4 Local Employment Sites and GAM5 New Employment Sites – However both policies contain similar considerations to be taken into account by a developer and it is not entirely sure what is the difference between these two polices other than GAM5 is allocating a site whereas GAM4 is identifying sites.

Both policies include the permitted uses of the various sites e.g., Use class E(g). But the new use classes (2020) allows the change of use within Use Class E without requiring consent so the policies cannot specify a specific element of Use class E. This would be contrary to national policy and therefore not meet a basic conditions test.

Object

Representation ID: 56603

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

GAM4 Local Employment Sites

Station Rd, Church Street, Drove Road and Green End Industrial sites are each treated slightly differently in Policy GAM4 Local Employment Sites. In our earlier comments we had suggested that each site should have its own separate policy. We are aware that each site has its own character and requirements and constraints. Proposals will need to be suitable in scale for each location. Those sites on the edge of the village will need different consideration to those within the village. The policy currently drafted says all proposals are expected to protect and safeguard landscape features and designations. Each employment site may have different requirements/ constraints which are not clearly shown within this policy. Our Economic Development Officer does not consider that the policy as currently worded makes it clear what is appropriate development for each site. Such clarity would help any developer/ business/planner understand the key site issues early on. This would help expedite any application process and avoid unnecessary costs for all parties. If the aim is to support local businesses, the provision of as much information as possible up front is important.

Drove Road is outside of the development framework boundary of the village The Local Plan Policy S/7: Development Frameworks allows for site allocations to be permitted outside of the framework if they are within a made neighbourhood plan. Further development at Drove Road in GAM4 could be contrary to this strategic policy in the Local Plan if it is not a specific allocation.

The Drove Road employment site appears to be shown as two distinct sites on Map 5A, but without specific identification this is an assumption having to be made by the user of the Plan. The existing policy had evolved to refer specifically to the expansion of businesses in situ. We are aware that there has been concerns about the proposals in the local community which led to the site being included in GAM4 rather than GAM5. It is stated in paragraph 4.47 that the Strategic Environmental Assessment (SEA) concluded that development of previously undeveloped land at Drove Road has increased potential to lead to the loss of productive agricultural land, has increased potential to impact on biodiversity habitats and local character without mitigation measures. Whilst Drove Road is not being designated as a new employment area and policy GAM11 refers to Biodiversity net gain, given the results of the SEA specifically reference Drove Road, we consider that there needs to be specific reference in GAM4 on mitigating the impact of the expansion of businesses on biodiversity habitats/biodiversity net gain.

For Drove Road there are specific criteria that must be followed if a development proposal is to be successful. In the supporting text the justification for permitting an increase of 25% of the existing footprint is that put forward by local businesses in the area. Would 25% be suitable for all buildings within the Drove Rd sites? It is unclear whether an assessment has been carried out to confirm this. If development has to follow specific design criteria to be of an appropriate scale (what scale is appropriate?) and integrated into the landscape (how to achieve this). It should be spelt out more clearly within the policy and explained in the supporting text. This will assist a developer to ensure a proposal meets the requirements of this policy and for a development management officer or the Planning Committee at SCDC to determine a planning application against this policy. Would a version of Local Plan Policy E/12: New Employment Development in Villages relating to just the expansion of existing premises on Drove Road be more straightforward or indeed would the Local Plan policy be sufficient? There could be an explanation of what is considered appropriate scale in the supporting text.

Object

Representation ID: 56604

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

GAM5 New employment site allocations

Mill Hill is the only site allocated in GAM5 so this policy could be site specific to Mill Hill. Is Mill Hill to be an Employment site or a Rural Business Development Area? Both terms are used within the policy.

Paragraph 4.53 – This mentions that there are two new rural business development areas being allocated in the Plan when within the Policy GAM5 there is only one.

We have previously expressed our concerns on the inclusion of the B8 use in the policy wording for both employment policies. This has now been removed from GAM4 but remains in GAM5. Would applications for development of B8 uses be approved on the Mill Hill site regardless of scale or specific location constraints? Without restrictions on the scale of development that would be supported this could result in large sheds and the associated traffic generation. The policy must be clear on what would be supported. Although it has been highlighted to us that such uses already exist on this site this policy criterion would be positively encouraging such a use. If this is the case it could be contrary to the Local Plan Policy E/11: Large Scale Warehousing and Distribution Centres. This is a strategic policy in the Local Plan. This policy would not meet the basic condition test about being in general conformity with the strategic policies in the Local Plan.

We continue to have concerns about the way the policy is drafted. It does not restrict the amount of employment use allowed in the Mill Hill area – this is not supported by SCDC. We are not sure what the parish council’s vision for this area is and how it is envisaged development would take place. Is it proposed to be piecemeal redevelopment on these sites or a comprehensive scheme? There would be implications for the provision of infrastructure to support such development. We would consider that if this site is to be developed comprehensively there should be a requirement included in the policy for a design framework or brief. A brief would help to shape the future development of the site and would be a useful tool to determine the appropriate capacity of the site identifying the constraints and opportunities of the site, setting out the design parameters for the layout and appearance, exploring improved connections and the impacts on existing infrastructure.

There are residential properties including a care home within the boundaries of the Mill Hill area. Whilst recognising that this policy now includes a section that states that any employment proposal has to demonstrate that there will be no adverse impacts on the rural environment and amenity or property of nearby residents, we remain concerned at the potential scale of development that could be allowed by this policy and controlling the amenity impact on nearby residents. We have previously suggested that the parish council should review the extent of what could be allowed by this policy

Support

Representation ID: 56605

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Community amenities and facilities

We consider that this section would have benefited from having the supporting text for each different policy being with the policy rather than part of a long introduction that includes many issues.

Object

Representation ID: 56606

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

GAM6 Community Facilities

We consider that the first part of this policy is not saying anything specific for Gamlingay as it just repeating the Local Plan protecting services and facilities (SC/3) or meeting community needs (SC/4). It is unclear why mention is made here of the support for the creation of additional sports pitches.

Support

Representation ID: 56607

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

GAM7 Designation of former First School buildings Green End

Map 9 - It would help if Map 9 only included the policies relevant to this part of the Plan. We are unsure what GAM1 Allocated Local Plan Site refers to as this policy does not allocate any sites. Also, open spaces are shown and there is no policy relating to these in the Plan unless these are the ones listed in Appendix 2

Object

Representation ID: 56608

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

GAM 8 Reuse of first school buildings

We suggest that rather than stating a set period over which the site is safeguarded and could remain empty that the site is safeguarded unless it can be demonstrated that the site has been marketed for a period at a realistic price for educational and community uses, and nothing has been forthcoming.

Within the policy the first sentence ends with a collection of letters as examples. (Eg. (a,b,e,f,g)) We are not clear what this means.

We have previously suggested that the policy could have as a requirement that a design guide/masterplan be prepared for the site. Such a brief could clarify policies and their application to the site. There may be different interests in the development of the site, and these may sometimes conflict. The preparation of a brief provides an opportunity for such conflicts to be resolved and provide sound urban design principles to the development of the site.

Object

Representation ID: 56609

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

GAM9 Transport provision

Does the car parking element of the policy forming the second part of the policy add anything specific for Gamlingay? The Local Plan Policy TI/3: Parking Provision is design led.

Second part of the policy – How will a housing development provide ‘enough car parking’ …within the ‘development envelope’. Enough is not defined anywhere nor is the development envelope. Development should be providing car parking in accordance with the adopted standards unless the Neighbourhood Plan suggests otherwise through robust evidence.

There is no evidence or mention in the supporting text to support why level multi use surfaces should be avoided – is this a particular problem in Gamlingay? Context and number of units served should influence the road layout. Shared surfaces streets influence driver behaviour to reduce vehicular speed and improve road safety. We consider that, without supporting evidence, this is overly prescriptive.

We also have concerns about this part of the policy from a historic environment perspective. At present, it is framed very rigidly, and we are anxious that it might inadvertently lead to heavily engineered layouts in very small-scale developments, especially small plots leading off the village’s central streets. At present, such developments often do have shared surfaces, and the VDG identifies some developments with shared surfaces as being successful. We consider that this section should be more flexible to avoid unintentional harm to the historic character of the village

Object

Representation ID: 56610

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

There has been discussions between the Section 106 officer and the parish council about this policy. He considers the principle of asking for contribution fine but that there needs to be a clear idea of what is to be included in the parish improvement plan for cycling etc. There are a number of issues that he considers need to be clarified.

Policy GAM10 mentions Map 10 – it is not clear whether the routes shown on this map are planned or existing routes to be improved. It is a map that includes other policies which distract from the cycling routes.

It is not clear whether the contributions set out in GAM10 are to be calculated on the gross internal floor area or gross external floor are. Are the contributions to be chargeable on extensions to existing business premises or whether (as currently worded) it is only chargeable on new units. Is there to be an intended floor on contributions (i.e. no contributions are payable where the total payable would be less than say £500?)

Clarification is needed as to whether the rates are subject to annual increase in indexation and if so which indexation is to be used. SCDC would suggest that indexation is applied annually from the date the plan is made by reference to BCIS All in Tender.

Policy GAM10 requires contributions of £21 per m2 of floor space (for business developments), and £10 per m2 of floor space (for housing developments). An explanation is needed as to why the housing contribution is £10 rather than £29 that Appendix 3 would suggest is the most appropriate figure to use. Consideration could be given to reducing the contribution for major developments where in kind works to provide new paths are required.

The plan should explain how much money is expected to be generated during the life of the plan, what alternative funding sources may exist and whether there are any particular priority areas in the event that the full amount is not secured.

The plan should explain whether there is County Council support for this proposal both in Cambridgeshire and Central Bedfordshire. We would imagine this is a key point to the implementation of the policy.

The plan should explain the delivery mechanism for provision of new footpaths, i.e. will this be direct Parish Council commissioning.

Support

Representation ID: 56611

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

4.6 Natural environment

It may help to have the supporting text included in the justification section to be directly linked to the policy placed in the Plan next to the relevant text.

Object

Representation ID: 56612

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

GAM11 Landscape and natural environment

The policy has evolved since the pre-submission draft. There is no explanation in the supporting text as to what is meant by the term ‘biodiversity metric tool’ which is referred to in the first sentence. The examples of biodiversity projects should be included in the supporting text rather than in the policy. It does not create a clear policy for implementing.

The first section of this policy refers to key ‘wildlife corridors...and a network of green spaces/infrastructure’ but the Plan does not provide a map to show where the existing corridors and green network are within the parish. Appendix 2 entitled Gamlingay’s green infrastructure does provide lists of different green features but unfortunately these have not been brought together in a map in the Plan. The VDG does show open space on page 14 which could have been included in the Plan to give added weight to protection of corridors. The VDG talks of green fingers of landscape from centre of village to rural edge – these could have been shown in a map in this Plan and thereby helped to protect them.

Last sentence of first section of the policy – We consider that the proposed network of green spaces should be for habitat creation and not just for sport and recreation.

The second section of the policy - The policy states that only housing and employment developments should not obstruct, or damage valued sites referred to – surely all development should protect these sites? It is not clear in the policy how the green spaces within a development are not to become isolated rather than linked to the wider green network of the parish especially if this is not mapped. How could this policy be implemented without identifying the green sites included in Appendix 2 on a map?

Object

Representation ID: 56613

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Our ecology officer considers that policy should refer to the fact that this wood is an ancient woodland. It is designated as an SSSI because it is an ancient woodland, so this designation is important.

The 200m cordon we understand is to allow for countryside uses for those using the woodland. This should be explained more clearly in the supporting text rather than simply stating it is the for the enjoyment of future generations but then mentioning in the policy that it is to allow for small scale sustainable construction for the traditional woodland industry. This needs to be explained and evidenced as to why the 200m cordon is chosen as opposed to some other distance.

Object

Representation ID: 56663

Received: 25/04/2024

Respondent: Mr J Richardson

Agent: Plainview Planning Ltd

GAM1

The Plan does not plan positively for housing growth.

The NP policy must be suitably flexibly worded to allow sustainable windfall development to come forward
in order to plan positively for housing growth across its lifetime.

The Plan does not make provision for rural exception sites.

A more flexible approach to smaller scale housing sites needs to be included within the Neighbourhood Plan.

Object

Representation ID: 56664

Received: 25/04/2024

Respondent: Mr J Richardson

Agent: Plainview Planning Ltd

GAM3

Does not agree that development should be restricted in the hamlets - this is not a proactive approach to achieving sustainable development.

Support

Representation ID: 56665

Received: 25/04/2024

Respondent: Mr J Richardson

Agent: Plainview Planning Ltd

GAM 6

Support need for additional outdoor space in Gamlingay.

the Plan is not flexible to allow for new sports facilities

Object

Representation ID: 56666

Received: 25/04/2024

Respondent: Mr J Richardson

Agent: Plainview Planning Ltd

Considers the evidence base supporting the Plan is not up to date.

Support

Representation ID: 56696

Received: 23/11/2021

Respondent: East of England Ambulance Service NHS Trust

Confirm our commitment to working in partnership with South Cambridgeshire Council and Cambridgeshire and Peterborough Clinical Commissioning Group to jointly plan the necessary infrastructure to help the local community in Gamlingay prosper.

Support

Representation ID: 58492

Received: 09/12/2021

Respondent: Cambridgeshire County Council

• Reference is made to the potential flood risks within Gamlingay, and the specific locations that are most at risk. It is also shown that the Neighbourhood plan supports increased resilience to flooding through the promotion of rainwater harvesting and flood mitigation using SuDS.
• It can be seen that reference has now been made to the NPPF, through the discussion of a proactive approach to mitigating and adapting to climate change. The use of Sustainable Urban Drainage Systems (SuDS) is also mentioned as a specific method of protecting watercourses.
• The Cambridgeshire Flood and Water Supplementary Planning Guidance is also included which will allow future developments to be built in ways that are considerate of flood risk and in line with adopted documentation.
• It may still be worth drawing attention to Policies CC/7, CC/8 and CC/9 in the South Cambridgeshire Local Plan as these relate to flood risk and are considered during planning application review.
• It is discussed throughout the Neighbourhood Plan the importance of increasing the biodiversity within the area, links could be made to the potential for increasing biodiversity through the use of SuDS features such as attenuation basins, ponds and swales.