Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 60345

Received: 10/12/2021

Respondent: F. C. Butler Trust

Agent: Cheffins

Representation Summary:

Land north of Station Road West/ East of Duxford Road, Whittlesford (HELAA site 59385)

The First Proposals plan is heavily reliant on the delivery of a handful of strategic developments, particularly large and complex sites which, on average, would take 5-8 years for the first home to be delivered. To ensure that housing delivery does not stall, and the affordability crisis worsened as a result, a pipeline of smaller developments which can deliver homes quickly will be needed in the short-to-medium term.

Comment

Greater Cambridge Local Plan Preferred Options

S/JH: New jobs and homes

Representation ID: 60346

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.

Comment

Greater Cambridge Local Plan Preferred Options

S/SB: Settlement boundaries

Representation ID: 60347

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.

Comment

Greater Cambridge Local Plan Preferred Options

CC/NZ: Net zero carbon new buildings

Representation ID: 60348

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).

Comment

Greater Cambridge Local Plan Preferred Options

CC/WE: Water efficiency in new developments

Representation ID: 60349

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.

Comment

Greater Cambridge Local Plan Preferred Options

BG/GI: Green infrastructure

Representation ID: 60350

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.

Comment

Greater Cambridge Local Plan Preferred Options

WS/HD: Creating healthy new developments

Representation ID: 60351

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).

Comment

Greater Cambridge Local Plan Preferred Options

GP/PP: People and place responsive design

Representation ID: 60352

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.

Comment

Greater Cambridge Local Plan Preferred Options

GP/QD: Achieving high quality development

Representation ID: 60353

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.

Comment

Greater Cambridge Local Plan Preferred Options

H/AH: Affordable housing

Representation ID: 60354

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.

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