Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

S/JH: New jobs and homes

Representation ID: 60335

Received: 10/12/2021

Respondent: F. C. Butler Trust

Agent: Cheffins

Representation Summary:

The widespread promotion of Neighbourhood Plans (page 24) is likely to act as a constraint on development in the rural area. Research on the progress and effectiveness of neighbourhood plans found that 55% of the draft plans published for consultation have 'protectionist' agendas and many are openly anti-development. Therefore, there is a likelihood that this agenda will create inevitable conflicts between the national aim to significantly boost housebuilding and local community NIMBYism. The idea of 'top down' housing targets being set by the local authority may also dissuade some areas from engaging with the neighbourhood planning process altogether.

Full text:

The widespread promotion of Neighbourhood Plans (page 24) is likely to act as a constraint on development in the rural area. Research on the progress and effectiveness of neighbourhood plans found that 55% of the draft plans published for consultation have 'protectionist' agendas and many are openly anti-development. Therefore, there is a likelihood that this agenda will create inevitable conflicts between the national aim to significantly boost housebuilding and local community NIMBYism. The idea of 'top down' housing targets being set by the local authority may also dissuade some areas from engaging with the neighbourhood planning process altogether.

Comment

Greater Cambridge Local Plan Preferred Options

S/SB: Settlement boundaries

Representation ID: 60336

Received: 10/12/2021

Respondent: F. C. Butler Trust

Agent: Cheffins

Representation Summary:

Although much of the Greater Cambridge area has a dispersed settlement pattern, the draft plan does not support the 'organic' growth of smaller settlements. A more flexible and tolerant approach is needed towards development in the rural area.
It is not logical to treat all sites equally in policy terms. The sensitive development of some sites on the edge of a village would cause no significant harm. Such a pragmatic approach is often taken at appeal.
For Group Villages, the current strategy to restrict developments within settlement boundaries will not deliver the quantum of development required to meet needs. As a result, the affordability crisis will deepen in the rural area.
A carefully worded criteria-based policy which was supportive of organic growth adjacent to existing built-up areas should not perpetuate unfettered incremental growth.

Full text:

Although much of the Greater Cambridge area has a dispersed settlement pattern, the draft plan does not support the 'organic' growth of smaller settlements. To ensure that local housing needs can be fulfilled and prevent any further loss of key local services, a more flexible and tolerant approach is needed towards development in the rural area.
Through the application of tightly drawn settlement boundaries, development is strictly controlled on sites in the 'open countryside'. But it is not logical to treat all sites equally in policy terms. Although sites within sensitive valued landscapes and the green belt should receive a high level of protection, the sensitive development of some sites on the edge of a village would cause no significant harm (e.g. Whittlesford). Such a pragmatic approach is often taken at appeal; rounding off development where there is a defensible physical boundary or allowing a high-quality development with extensive landscaping that would soften an existing harsh area of built form can be acceptable in certain locations.
Furthermore, for Group Villages such as Whittlesford and Whittlesford Bridge, the current strategy to restrict developments to an indicative maximum of 8 dwellings (or 15 dwellings where this would make the best use of a single brownfield site) within settlement boundaries will not deliver the quantum of development required to meet the existing need for affordable homes or the projected need that could follow nearby business park expansions. As a result, the affordability crisis will deepen in the rural area. For example, to deliver 25 affordable homes within Whittlesford, a minimum of 63 dwellings will need to be permitted as part of major developments. With limited scope for development within the tightly drawn settlement boundary, it will be necessary to find suitable locations on the edge of the village. To discourage the development of less suitable sites and assist in the delivery of much­ needed affordable housing, the most logical approach is to allocate further sites on the edge of sustainable settlements such as Whittlesford Bridge.
Overall, a carefully worded criteria-based policy which was supportive of organic growth adjacent to existing built-up areas should not perpetuate unfettered incremental growth.

Comment

Greater Cambridge Local Plan Preferred Options

CC/NZ: Net zero carbon new buildings

Representation ID: 60337

Received: 10/12/2021

Respondent: F. C. Butler Trust

Agent: Cheffins

Representation Summary:

Draft Policy CC/NZ sets a high threshold of 150 homes for calculating whole life carbon emissions. Support should also be expressed for developments of <150 dwellings where this information is provided voluntarily.
What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in a supplementary planning document (SPD).

Full text:

Draft Policy CC/NZ sets a high threshold of 150 homes for calculating whole life carbon emissions. Support should also be expressed for developments of <150 dwellings where this information is provided voluntarily.
What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in a supplementary planning document (SPD).

Comment

Greater Cambridge Local Plan Preferred Options

CC/WE: Water efficiency in new developments

Representation ID: 60338

Received: 10/12/2021

Respondent: F. C. Butler Trust

Agent: Cheffins

Representation Summary:

What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in an SPD.

Full text:

What support will be available for developers in seeking to meet the high standards proposed? Will the potential impact on viability be taken into consideration? Regardless of the chosen approach, it would be useful to include further guidance/information in an SPD.

Comment

Greater Cambridge Local Plan Preferred Options

BG/GI: Green infrastructure

Representation ID: 60339

Received: 10/12/2021

Respondent: F. C. Butler Trust

Agent: Cheffins

Representation Summary:

The adoption of a green infrastructure standard should be a recommendation, not a requirement. Developments should not be opposed where all reasonable steps have been taken to protect and incorporate green infrastructure.
Regardless of the chosen approach, it would be useful to include further guidance/information in an SPD.

Full text:

The adoption of a green infrastructure standard should be a recommendation, not a requirement. Developments should not be opposed where all reasonable steps have been taken to protect and incorporate green infrastructure.
Regardless of the chosen approach, it would be useful to include further guidance/information in an SPD.

Comment

Greater Cambridge Local Plan Preferred Options

WS/HD: Creating healthy new developments

Representation ID: 60340

Received: 10/12/2021

Respondent: F. C. Butler Trust

Agent: Cheffins

Representation Summary:

Health Impact Assessments should be a requirement for major developments only. For minor developments, this information should be optional or simplified, for example through the use of a short questionnaire (similar to the Cambridgeshire Biodiversity Checklist).

Full text:

Health Impact Assessments should be a requirement for major developments only. For minor developments, this information should be optional or simplified, for example through the use of a short questionnaire (similar to the Cambridgeshire Biodiversity Checklist).

Comment

Greater Cambridge Local Plan Preferred Options

GP/PP: People and place responsive design

Representation ID: 60341

Received: 10/12/2021

Respondent: F. C. Butler Trust

Agent: Cheffins

Representation Summary:

It is unusual to have two separate policies on design. Good design is highly subjective. However, the planning system has allowed the steady homogenisation of built environments. Design Guides/Codes are acceptable on large scale, strategic developments, but should not be imposed on smaller scale developments where other mechanisms can adequately achieve similar and proportionate outcomes. It will take time for these design guides to be drafted and adopted. In the interim, developers could be signposted towards an alternative framework, such as the National Design Guide. Developments which can demonstrate a high standard of design should be fast­ tracked through the application process. Additional measures should be introduced for strategic scale development to avoid monotony.

Full text:

Firstly, it is unusual to have two separate policies on design.
It is accepted that good design is highly subjective. However, the planning system has allowed the steady homogenisation of built environments, with a dominance of bland, monotonous "identikit" housing estates from major housebuilders.
Design Guides/Codes are acceptable on large scale, strategic developments, but should not be imposed on smaller scale developments where other mechanisms, including parameter plans, can adequately achieve similar and proportionate outcomes. Local community input will also be as stated, and a robust consultation process will be needed since the 'devil will be in the detail'; these documents must go well beyond broad requirements for new homes to be 'in keeping' with the character and appearance of the area.
However, it will take time for these design guides to be drafted and adopted. In the interim, developers could be signposted towards an alternative framework, such as the National Design Guide, which includes 10 characteristics of a well-designed place: context, identity, built form, movement, nature, public spaces, uses, homes and buildings, resources, and lifespan. Developments which can demonstrate a high standard of design should be fast­ tracked through the application process.
Additional measures should be introduced for strategic scale development to avoid monotony. For example, the policy could introduce a minimum number of individual house types, appropriate to the scale of development.

Comment

Greater Cambridge Local Plan Preferred Options

GP/QD: Achieving high quality development

Representation ID: 60342

Received: 10/12/2021

Respondent: F. C. Butler Trust

Agent: Cheffins

Representation Summary:

It is unusual to have two separate policies on design. Good design is highly subjective. However, the planning system has allowed the steady homogenisation of built environments. Design Guides/Codes are acceptable on large scale, strategic developments, but should not be imposed on smaller scale developments where other mechanisms can adequately achieve similar and proportionate outcomes. It will take time for these design guides to be drafted and adopted. In the interim, developers could be signposted towards an alternative framework, such as the National Design Guide. Developments which can demonstrate a high standard of design should be fast­ tracked through the application process. Additional measures should be introduced for strategic scale development to avoid monotony.

Full text:

Firstly, it is unusual to have two separate policies on design.
It is accepted that good design is highly subjective. However, the planning system has allowed the steady homogenisation of built environments, with a dominance of bland, monotonous "identikit" housing estates from major housebuilders.
Design Guides/Codes are acceptable on large scale, strategic developments, but should not be imposed on smaller scale developments where other mechanisms, including parameter plans, can adequately achieve similar and proportionate outcomes. Local community input will also be as stated, and a robust consultation process will be needed since the 'devil will be in the detail'; these documents must go well beyond broad requirements for new homes to be 'in keeping' with the character and appearance of the area.
However, it will take time for these design guides to be drafted and adopted. In the interim, developers could be signposted towards an alternative framework, such as the National Design Guide, which includes 10 characteristics of a well-designed place: context, identity, built form, movement, nature, public spaces, uses, homes and buildings, resources, and lifespan. Developments which can demonstrate a high standard of design should be fast­ tracked through the application process.
Additional measures should be introduced for strategic scale development to avoid monotony. For example, the policy could introduce a minimum number of individual house types, appropriate to the scale of development.

Comment

Greater Cambridge Local Plan Preferred Options

H/AH: Affordable housing

Representation ID: 60343

Received: 10/12/2021

Respondent: F. C. Butler Trust

Agent: Cheffins

Representation Summary:

The plan sets a challenging target for affordable housing to reflect the acute and substantial need for affordable housing. This places a great responsibility on all major developments to provide an element of affordable housing.
Policy H/AH will have a significant bearing on the viability of individual residential developments, so it is vital that the affordable housing requirement is achievable in practice. Although the plan indicates that viability evidence will be reviewed as appropriate as part of the plan-making process, this is not sufficient. Planning Practice Guidance indicates that plans should set out circumstances where review mechanisms may be appropriate, as well as a clear process and terms of engagement regarding how and when viability will be reassessed over the lifetime of a development. Draft Policy H/AH does not do this.
Dependence on the allocation of strategic sites with already high infrastructure burdens is unlikely to offer sustainable, long-term solutions to the chronic and worsening affordability issues. More smaller sites that are far more likely to deliver a policy-compliant level of affordable homes at a faster rate need to be allocated.

Full text:

The First Proposals plan sets a challenging target for affordable housing to reflect the acute and substantial need for affordable housing across Greater Cambridge. This places a great responsibility on all major developments to provide an element of affordable housing.
Policy H/AH will have a significant bearing on the viability of individual residential developments, so it is vital that the affordable housing requirement is achievable in practice. Although the First Proposals plan indicates that viability evidence will be reviewed as appropriate as part of the plan-making process, this is not sufficient. Planning Practice Guidance indicates that plans should set out circumstances where review mechanisms may be appropriate, as well as a clear process and terms of engagement regarding how and when viability will be reassessed over the lifetime of a development to ensure policy compliance and optimal public benefits through economic cycles. Draft Policy H/AH does not do this - changes in affordable housing tenure models or continued increases in build costs may render the viability evidence which underpins the affordable housing requirement out-of-date relatively quickly.
Dependence on the allocation of strategic sites with already high infrastructure burdens is unlikely to offer sustainable, long-term solutions to the chronic and worsening affordability issues manifesting across the Greater Cambridge area. Strategic sites alone do not deliver policy-compliant levels of affordable housing, so, if this is the target, more smaller sites that are far more likely to deliver a policy-compliant level of affordable homes at a faster rate need to be allocated.

Comment

Greater Cambridge Local Plan Preferred Options

H/CB: Self and custom build homes

Representation ID: 60344

Received: 10/12/2021

Respondent: F. C. Butler Trust

Agent: Cheffins

Representation Summary:

The proposed policy approach will require continual updating of the self and custom build register(s) to reflect the permissions that have been granted with a self- or custom-build element. Close monitoring on sales and completions will also be necessary in case plots earmarked for self- or custom-build revert to market dwellings at the end of the prescribed 12-month marketing period.
It is also unclear if the current registers for Cambridge City and South Cambridgeshire are to be combined, with delivery of plots across the wider area. This would not be logical since many prospective self-builders will have preferred locations and few will have a search area as wide as Greater Cambridge. A more focused policy, perhaps split across the two administrative areas, would encourage the development of self-build plots in the right locations to meet local demand.

Full text:

The proposed policy approach will require continual updating of the self and custom build register(s) to reflect the permissions that have been granted with a self- or custom-build element. Close monitoring on sales and completions will also be necessary in case plots earmarked for self- or custom-build revert to market dwellings at the end of the prescribed 12-month marketing period.
It is also unclear if the current registers for Cambridge City and South Cambridgeshire are to be combined, with delivery of plots across the wider area. This would not be logical since many prospective self-builders will have preferred locations and few will have a search area as wide as Greater Cambridge. A more focused policy, perhaps split across the two administrative areas, would encourage the development of self-build plots in the right locations to meet local demand. For example, if all the need for plots was in and around Cambridge, it would not make sense to burden developers in other parts of the area.

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