Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 60284

Received: 13/12/2021

Respondent: Wheatley Group Developments Ltd

Agent: Cheffins

Representation Summary:

Land West of Elizabeth Way, Gamlingay (HELAA site 40300)

There are no proposed allocations in Gamlingay, and very little residential development proposed for the rural areas - questions whether the Council will meet the NPPF target for small and medium sized sites (paragraph 69). The GCLP needs to provide for a range of different housing needs which allows smaller settlements and rural areas to continue to thrive (paragraph 79 of the NPPF).

There is also a need for sites to be allocated which can deliver the required level of affordable housing which is a needed both in the urban and rural areas. 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. Strategic sites alone do not deliver policy-compliant levels of affordable housing, so, more smaller sites need to be allocated.

Full text:

There are no proposed allocations in Gamlingay as part of the emerging GCLP, and very little residential development proposed for the rural areas as a whole which questions whether the Council will meet the NPPF target of delivering at least 10% of their housing requirement on small and medium sized sites (as set out within paragraph 69 of the NPPF). Land to the West of Elizabeth Way, Gamlingay would provide a sustainable medium sized site providing much needed affordable housing. The GCLP needs to provide for a range of different housing needs which allows smaller settlements and rural areas to continue to thrive. This is in accordance with Paragraph 79 of the NPPF which seeks to promote sustainable development in rural areas by locating housing growth where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive.

There is also a need for sites to be allocated which can deliver the required level of affordable housing which is a need both in the urban and rural areas. According to recent housing needs projections, an annual net need of 435 affordable rental units and 105 affordable units for homeownership will be needed across South Cambridgeshire to satisfy housing demands. 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.

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. Site 40300, Land West of Elizabeth Way, Gamlingay is suitable, available, and deliverable within 0-5 years.

Comment

Greater Cambridge Local Plan Preferred Options

S/SB: Settlement boundaries

Representation ID: 60285

Received: 13/12/2021

Respondent: Wheatley Group Developments Ltd

Agent: Cheffins

Representation Summary:

Land to the West of Elizabeth Way, Gamlingay (HELAA site 40030)

Although much of the Greater Cambridge area has a dispersed settlement pattern, the plan does not support the 'organic' growth of smaller settlements. To ensure that local housing needs can be fulfilled and to prevent any further loss of key local services, a more flexible and tolerant approach is needed towards development in the rural area.

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.

A carefully worded criteria-based policy which is supportive of organic growth adjacent to existing built-up areas would allow rural areas to thrive and is in accordance with the aims of NPPF paragraph 79.

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. The sensitive development of some sites on the edge of a village would cause no significant harm (e.g. Land West of Elizabeth Way, Gamlingay). 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 Minor Rural Centres such as Gamlingay the current strategy to restrict developments to an indicative maximum of 30 dwellings within settlement boundaries will not deliver the quantum of development required to meet the existing need for affordable homes as there are few opportunities for the development of sites within the existing settlement. 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 villages such as Gamlingay.

Overall, a carefully worded criteria-based policy which is supportive of organic growth adjacent to existing built-up areas would allow rural areas to thrive and is in accordance with the aims of NPPF paragraph 79 which seeks to promote sustainable development in rural areas by locating housing growth where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive.

Comment

Greater Cambridge Local Plan Preferred Options

CC/NZ: Net zero carbon new buildings

Representation ID: 60286

Received: 13/12/2021

Respondent: Wheatley Group Developments Ltd

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: 60287

Received: 13/12/2021

Respondent: Wheatley Group Developments Ltd

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: 60288

Received: 13/12/2021

Respondent: Wheatley Group Developments Ltd

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: 60289

Received: 13/12/2021

Respondent: Wheatley Group Developments Ltd

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: 60290

Received: 13/12/2021

Respondent: Wheatley Group Developments Ltd

Agent: Cheffins

Representation Summary:

It is accepted that good design is highly subjective. However, the planning system has allowed the steady homogenisation of built environments.

The bold ambitions of draft policy GP/PP are supported, particularly the proposed use of design Guides/Codes to set out the design expectations for a particular area. 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. Developments which can demonstrate a high standard of design should be fast­ tracked through the application process.

Full text:

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.

The bold ambitions of draft policy GP/PP are supported, particularly the proposed use of design Guides/Codes to set out the design expectations for a particular area. 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.

Comment

Greater Cambridge Local Plan Preferred Options

GP/QD: Achieving high quality development

Representation ID: 60291

Received: 13/12/2021

Respondent: Wheatley Group Developments Ltd

Agent: Cheffins

Representation Summary:

It is accepted that good design is highly subjective. However, the planning system has allowed the steady homogenisation of built environments.

The bold ambitions of draft policy GP/PP are supported, particularly the proposed use of design Guides/Codes to set out the design expectations for a particular area. 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. Developments which can demonstrate a high standard of design should be fast­ tracked through the application process.

Full text:

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.

The bold ambitions of draft policy GP/PP are supported, particularly the proposed use of design Guides/Codes to set out the design expectations for a particular area. 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.

Comment

Greater Cambridge Local Plan Preferred Options

H/AH: Affordable housing

Representation ID: 60292

Received: 13/12/2021

Respondent: Wheatley Group Developments Ltd

Agent: Cheffins

Representation Summary:

Policy H/AH will have a significant bearing on the viability of individual 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 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 - 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.

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.

Draft Policy H/AH of the First Proposals plan requires 40% affordable housing on sites of 10 or more dwellings. With a total of 45 dwellings,18 dwellings would be sought for affordable housing under this policy (as shown on the Indicative Site Plan). As well as helping to address the current shortage of affordable housing over the Greater Cambridge area, the delivery of up to 78 affordable dwellings would represent a considerable contribution to the social sustainability of the local area.

Comment

Greater Cambridge Local Plan Preferred Options

S/RRA: Allocations in the rest of the rural area

Representation ID: 60718

Received: 13/12/2021

Respondent: Wheatley Group Developments Ltd

Agent: Cheffins

Representation Summary:

Land to the West of Elizabeth Way, Gamlingay (HELAA site 40030)

Although much of the Greater Cambridge area has a dispersed settlement pattern, the plan does not support the 'organic' growth of smaller settlements. To ensure that local housing needs can be fulfilled and to prevent any further loss of key local services, a more flexible and tolerant approach is needed towards development in the rural area.

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.

A carefully worded criteria-based policy which is supportive of organic growth adjacent to existing built-up areas would allow rural areas to thrive and is in accordance with the aims of NPPF paragraph 79.

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. The sensitive development of some sites on the edge of a village would cause no significant harm (e.g. Land West of Elizabeth Way, Gamlingay). 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 Minor Rural Centres such as Gamlingay the current strategy to restrict developments to an indicative maximum of 30 dwellings within settlement boundaries will not deliver the quantum of development required to meet the existing need for affordable homes as there are few opportunities for the development of sites within the existing settlement. 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 villages such as Gamlingay.

Overall, a carefully worded criteria-based policy which is supportive of organic growth adjacent to existing built-up areas would allow rural areas to thrive and is in accordance with the aims of NPPF paragraph 79 which seeks to promote sustainable development in rural areas by locating housing growth where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive.

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