Greater Cambridge Local Plan Preferred Options

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Comment

Greater Cambridge Local Plan Preferred Options

S/SH: Settlement hierarchy

Representation ID: 58548

Received: 13/12/2021

Respondent: Croudace Homes

Agent: Optimis Consulting Ltd

Representation Summary:

Policy S/SH Settlement Hierarchy (P48)
Given the range of services and facilities we support Fowlmere’s continued identification as a Group Village over and above an infill village. It is not clear however why the level of housing to come forward in such locations need be pre-judge i.e. ceiling of 8 units or exceptionally 15.

Recommendation: Policy should allow for development in Group Villages up to a scale that can be demonstrated to support and enhance the village moving forward.

Full text:

Policy S/SH Settlement Hierarchy (P48)
Given the range of services and facilities we support Fowlmere’s continued identification as a Group Village over and above an infill village. It is not clear however why the level of housing to come forward in such locations need be pre-judge i.e. ceiling of 8 units or exceptionally 15.

Recommendation: Policy should allow for development in Group Villages up to a scale that can be demonstrated to support and enhance the village moving forward.

Comment

Greater Cambridge Local Plan Preferred Options

S/SB: Settlement boundaries

Representation ID: 58551

Received: 13/12/2021

Respondent: Croudace Homes

Agent: Optimis Consulting Ltd

Representation Summary:

Recommendation: Policy should not put a blanket ban on development outside of the settlement boundary, in effect pre-judging any such proposal, rather it should set out a series of criteria allowing development where needed to support and enhance a village location to be assessed on its respective merits.

Full text:

Policy S/SB Settlement Boundary (P51)

We acknowledge a requirement to identify existing settlements and their boundaries. It should be acknowledged however that this reflects a snapshot in time. A blanket ban should not be adopted on development outside of the settlement boundaries, as is in effect currently proposed. Rather policy should allow for the consideration of all future proposals on their respective merits in line with the NPPF.

Recommendation: Policy should not put a blanket ban on development outside of the settlement boundary, in effect pre-judging any such proposal, rather it should set out a series of criteria allowing development where needed to support and enhance a village location to be assessed on its respective merits.

Comment

Greater Cambridge Local Plan Preferred Options

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

Representation ID: 58552

Received: 13/12/2021

Respondent: Croudace Homes

Agent: Optimis Consulting Ltd

Representation Summary:

Land at Long Lane, Fowlmere (HELAA site 59408)

Further allocations in rural areas are strongly encouraged.

Recommendation: The Plan must acknowledge the benefits of allowing a proportion of the plan period growth in rural areas and should proactively promote sites such as Long Lane, Fowlmere as appropriate locations for future development well placed to support local communities.

Full text:

Policy S/RRA (P123)

Further allocations in rural areas are strongly encouraged.

Recommendation: The Plan must acknowledge the benefits of allowing a proportion of the plan period growth in rural areas and should proactively promote sites such as Long Lane, Fowlmere as appropriate locations for future development well placed to support local communities.

Attachments:

Comment

Greater Cambridge Local Plan Preferred Options

CC/NZ: Net zero carbon new buildings

Representation ID: 58557

Received: 13/12/2021

Respondent: Croudace Homes

Agent: Optimis Consulting Ltd

Representation Summary:

Recommendation: Support

Full text:

Policy CC/N2 – Net Zero Carbon New Buildings (P145) and Policy CC/DC – Designing for a Challenging Environment (P152)

These policies seek to set the amount of energy use that will be allowed in new development and to ensure that all new dwellings must be designed to achieve a low risk of overheating.

Croudace Homes support such initiatives. They are already developing to the standard of New Homes and fully intended to deliver housing at Fowlmere, were it to come forward, to the highest building and sustainability standards.

These and the other environmental policies demonstrate that development should not be promoted on the basis of transport links alone, but rather wider regard has to be had to the scope of the site for development of the highest sustainability standards in terms of energy consumption, access to renewable and sensitivity to, and ability to work with, the immediate environment.

Recommendation: Support

Comment

Greater Cambridge Local Plan Preferred Options

CC/DC: Designing for a changing climate

Representation ID: 58559

Received: 13/12/2021

Respondent: Croudace Homes

Agent: Optimis Consulting Ltd

Representation Summary:

Recommendation: Support

Full text:

Policy CC/N2 – Net Zero Carbon New Buildings (P145) and Policy CC/DC – Designing for a Challenging Environment (P152)

These policies seek to set the amount of energy use that will be allowed in new development and to ensure that all new dwellings must be designed to achieve a low risk of overheating.

Croudace Homes support such initiatives. They are already developing to the standard of New Homes and fully intended to deliver housing at Fowlmere, were it to come forward, to the highest building and sustainability standards.

These and the other environmental policies demonstrate that development should not be promoted on the basis of transport links alone, but rather wider regard has to be had to the scope of the site for development of the highest sustainability standards in terms of energy consumption, access to renewable and sensitivity to, and ability to work with, the immediate environment.

Recommendation: Support

Comment

Greater Cambridge Local Plan Preferred Options

BG/BG: Biodiversity and geodiversity

Representation ID: 58562

Received: 13/12/2021

Respondent: Croudace Homes

Agent: Optimis Consulting Ltd

Representation Summary:

Recommendation: It is strongly recommended that the policy is amended to require no greater then a 10% net gain in bio-diversity, as per the approach established through the Environment Act.

Full text:

Policy BG/BG: Biodiversity and Geodiversity (P168)

No sound basis has been provided for the requirement for a 20% net gain in biodiversity proposed under this policy.

The Government considers a 10% net gain sufficient to mitigate the impact of new development and it should be recognised that the Environment Act does not set this as a minimum. No basis is presented therefore as to why Greater Cambridge should adopt a different approach to the other areas of the Country.

Recommendation: It is strongly recommended that the policy is amended to require no greater then a 10% net gain in bio-diversity, as per the approach established through the Environment Act.

Comment

Greater Cambridge Local Plan Preferred Options

How much development and where?

Representation ID: 58564

Received: 13/12/2021

Respondent: Croudace Homes

Agent: Optimis Consulting Ltd

Representation Summary:

Recommendation: We strongly encourage that housing provision is facilitated in village locations that allows such settlements to grow comparatively alongside the strategic locations identified for growth.

Full text:

2.1: How much Development and Where? (P22)

We support suggestion that the Greater Cambridge Plan wants “our rural villages to continue to thrive and sustain their local services…” We object however to subsequent suggestion that the plan actively seeks not to “encourage lots of new houses in places where car travel is the easiest or only way to get around.”

The provision of the appropriate number of new houses within rural Cambridge will be fundamental to ensuring villages thrive and survive. If the vast majority of growth is to be focused in a few strategic locations then it is clear that both the sphere of influence of such areas will grow and present threat to village facilities and the lack of growth will hinder further villages ability to support their communities.

The strategy pre-supposes that sustainability policy should be driven by transport considerations alone. How people work and live are evolving rapidly. Travel is only one issue that must be considered in the overall sustainability of future housing provision.

Recommendation: We strongly encourage that housing provision is facilitated in village locations that allows such settlements to grow comparatively alongside the strategic locations identified for growth.

Comment

Greater Cambridge Local Plan Preferred Options

Rest of the rural area

Representation ID: 58572

Received: 13/12/2021

Respondent: Croudace Homes

Agent: Optimis Consulting Ltd

Representation Summary:

Recommendation: The Plan must acknowledge the benefits of allowing a proportion of the plan period growth in rural areas and should proactively promote sites such as Long Lane, Fowlmere as appropriate locations for future development well placed to benefit from existing bus services and support the local community.

Full text:

2.6 Rest of Rural Area (P122)

The Plan states that ‘We want our rural villages to continue to thrive and sustain their local services, but we don’t want to encourage lots of new homes in places where car travel is the easiest or only way to get around.’

As per the above, in terms of ensuring that rural villages ‘thrive’ we consider that the plan should be proactive in allocating some of the anticipated growth in the region to these village locations. Where development is considered important to contribute to the vitality of a village location, it is important that is it assessed against a series of criteria. Transportation will be an important factor in any such consideration obviously but in terms of sustainability this should not be the sole consideration. Equally, it should be recognised that village locations do still have access to bus facilities and this should be factored in consideration of any site. Indeed one key reason for managed growth in village locations is to further support and safeguard existing bus services.

Recommendation: The Plan must acknowledge the benefits of allowing a proportion of the plan period growth in rural areas and should proactively promote sites such as Long Lane, Fowlmere as appropriate locations for future development well placed to benefit from existing bus services and support the local community.

Attachments:

Comment

Greater Cambridge Local Plan Preferred Options

S/DS: Development strategy

Representation ID: 59252

Received: 13/12/2021

Respondent: Croudace Homes

Agent: Optimis Consulting Ltd

Representation Summary:

Land to north east of Long Lane, Fowlmere (HELAA sites 40012, 40039 & 51059)

Recommendation: Village locations can provide sustainable locations for growth coupled with an ability to support existing communities. This should be acknowledged within policy. The need for growth in these places to sustain and help these existing settlements thrive should also be acknowledged.
The Spatial Strategy should seek to proactively plan for growth in village locations and should make clear that growth will be encouraged in village locations where it is shown appropriate to support and enhance the village moving forward.
Land at Long Lane Fowlmere be identified as a site suitable for the development of up to 130 new homes.

Full text:

Policy S/DS – Development Strategy (P29)
We support the proposed development strategy for Greater Cambridge in seeking to “direct development to where it has the least climate impact, where active and public transport is the natural choice, where green infrastructure can be delivered alongside new development, and where jobs, services and facilities can be located near to where people live, whilst ensuring all necessary utilities can be provided in a sustainable way.”
We do not agree however that this necessary dictate that a ‘very limited amount of development’ come forward in rural areas. The development strategy as proposed is overly reliant on strategic allocations. It does not consider what may happen to 5 year housing supply if these limited locations encounter delivery issues.
Whilst the plan allows for the development of sites of up to 8 and possible 15 in exceptional circumstances it is anticipated that these will come forward on a windfall basis. It is considered that the plan should be more proactive spatially in terms of ensuring that a proportion of housing need generally is used to underpin and safeguard the vitality of village locations going forward.
Indeed, on this the strategy goes onto state that ‘we have identified a limited number of new sites for housing at our more sustainable villages’. This appears to demonstrate that proactively planning for growth in village locations is beneficially however it is not then clear why these villages have been deemed appropriate for allocated development whilst villages such as Fowlmere are not.
Fowlmere continues to be classified as a Group Village within the emerging Local Plan, and whilst this is not necessarily considered the focus for strategic growth, modest growth is important in supporting, sustaining and enhancing local amenities and services.
Delivering extensions to existing communities and continuing to build on the strong cultural and social aspects of the larger settlements is vital in the progress towards achieving healthier communities. Proposing modern homes that create improved sustainable credentials and add vitality to existing neighbourhoods is not only a requirement of local and regional policy, but one that is adopted within the National Planning Policy Framework.
Limiting growth to larger settlements presents risks with regards to disproportionate settlements that could leave smaller villages, such as Fowlmere, with stagnated growth and poor support for local facilities.
Much of south Cambridgeshire is protected by Green Belt. Fowlmere falls outside of the Green Belt and the accommodation of development there offers the added benefit of not needing to remove further parcels of land from Green Belt designation.
It is considered that the development of Land off Long Lane, Folwmere can valuably contribute to the Greater Cambridge housing requirement whilst supporting and contributing to the Fowlmere local community. In this respect a site that is immediately developable, with minimal site-specific constraints, presents a positive opportunity for residential development that should be fully considered.
The site was submitted in response to Greater Cambridge’s call for sites (ref: 40012). In response Greater Cambridge concluded that that whilst the site was available and achievable it was not suitable. Much technical assessment of the site has subsequently taken place. As shown on the concept plan, submitted alongside these representations, it is considered that all technical issues relating to development of the site can be overcome and in this respect the site is considered suitable for development. This is expanded on below in the context of some of the key obstacles identified by the Council:
• Adopted Development Plan Policies: Assessed Amber on the basis that the site sits outside the development framework for Fowlmere as currently defined. The purpose of the emerging Greater Cambridge Plan however is to identify what sites are needed to meet housing supply have regard to the need to proactively identify sites and remove policy constraints as necessary. Within an emerging Local Plan therefore a settlement boundary need not be a barrier to suitability;
• Flood Risk: Again this has previously been assessed amber. It is acknowledged that part of the site is in flood risk zone 2 and 3. However, as shown on the attached concept plan technical analysis has confirmed that the site can come forward for development outside of these areas. In short flood risk does not prejudice the sites suitability for development;
• Landscape and Townscape. This was assessed to be Red given the potential impact on the village form and townscape of Fowlmere. Much design work has been undertaken to consider how residential development could come forward on the site in a manner that is sensitive to both the built form of Fowlmere and the streetscene itself. The Council’s assessment appears to pre-judge the site solely on the principle of its location outside of the existing settlement framework. In design terms it is considered that the site could come forward without significant impact in both landscape and townscape terms. This is not considered an issue that should cut to the principle of development on the site and not an issue therefore that can at this initial stage i.e. without consideration of detailed proposals, deem the site to be unsuitable;
• Bio-diversity and Geo-diversity: Again this has been assessed Amber but it is not clear on what basis. As the concept plan submitted alongside these representations shows the site allows for ample provision of green space. The delivery of new and enhanced open space within the site will include areas of native planting, wildflowers and trees and will assist in strengthening biodiversity in this location. The site is currently arable and as such offers only limited ecological value. Development of the site will delivery a net bio-diversity gain, in line with policy aspirations;
• Historic Environment. This has been assessed Amber on the basis that the site is within 100m of a listed building. The Concept Plan attached to these representations however shows that this relationship can be treated sensitively, in this instance a buffer is shown between and development and the sited asset. Again this is not considered an issue that need cut to the principle of development but rather one that can be handled sufficiently sensitively through the consideration of detailed proposals;
• Accessibility to Services and Facilities: This has been assessed as Red and as such a major issue in terms of the suitability of the site. All of the Local Amenities within Fowlmere are within a 10 minute walk and as such are accessible. Furthermore, development of the site offers the opportunity to provide important economic support to safeguard these facilities and the potential, in this respect, to provide support for further services.
• Site Access: It is not clear why this has been assessed as orange when the assessment concludes that access to the site is ‘ acceptable in principle’. Technical work has further confirmed this. Development of the site can be appropriately accessed;
• Transport and Roads: Fowlmere, as a village, is sustainably located and benefits from a number of facilities and amenities within a 10-minute walk of the site. With regards to transport connections Fowlmere is served by two bus services with the 915 bus service passing directly in front of the site connecting Fowlmere with Cambridge and Royston. In terms of village locations the site is fully accessible. This is not a barrier to development and indeed it is considered that the ability to use the development of this site to help contribute towards and safeguard these transport services should be reviewed further.
Overall, given the village’s sustainable location, combined with the district’s growth targets and housing delivery requirements set out within the new Local Plan, it is considered that land off Long Lane, Fowlmere, presents an appropriate location for additional housing. The site is bounded by logical and permanent boundaries and lacks substantial constraints. Further, the site is capable of delivering enhancements to open space and biodiversity. We strongly urge the Council to review the opportunity presented by the site.

Recommendation: Village locations can provide sustainable locations for growth coupled with an ability to support existing communities, services and facilities. This should be acknowledged within policy. The need for growth in these places to sustain and help these existing settlements thrive should also be acknowledged.
The Spatial Strategy should seek to proactively plan for growth in village locations and should make clear that growth will be encouraged in village locations where it is shown appropriate to support and enhance the village moving forward.
Land at Long Lane Fowlmere be identified as a site suitable for the development of up to 130 new homes.

Comment

Greater Cambridge Local Plan Preferred Options

STRATEGY

Representation ID: 59260

Received: 13/12/2021

Respondent: Croudace Homes

Agent: Optimis Consulting Ltd

Representation Summary:

Recommendation: Support

Recommendation: Where an appropriate case can be made, in the context of national planning policy, Neighbourhood Plans should be afforded the ability to bring forward housing developments appropriate to their needs and objectives.

Recommendation: A refined strategy should be considered that allows an appropriate proportion of growth to take place in sustainable village locations to compliment that being focused to strategic allocations.

Full text:

Section 2 Aims (P21):

We support the aims of the Greater Cambridge Local Plan, as set out at Section 2 of the Plan, to respond to:

• Climate Change;
• Bio-Diversity & Green Spaces;
• Wellbing and Social Inclusion;
• Great Places;
• Jobs;
• Homes; and
• Infrastructure.

Recommendation: Support

Neighbourhood Plan Housing Targets (P27)

Neighbourhood planning is specifically aimed at ensuring communities retain direct power to develop a shared vision for their neighbourhood and shape the development and growth of their local area. It seems wholly inappropriate therefore for the Greater Cambridge Plan to centralise these decisions stating that “…As such we are not relying on neighbourhood areas providing additional homes to meet our requirements.”

Recommendation: Where an appropriate case can be made, in the context of national planning policy, Neighbourhood Plans should be afforded the ability to bring forward housing developments appropriate to their needs and objectives.

What Alternatives did we Consider (P28)

It is not clear that alternative patterns of growth were considered in preparing the plan. In particular it is not clear if the Plan has considered the benefits of allowing an appropriate proportion of future growth to be located in rural areas to support existing villages.

Recommendation: A refined strategy should be considered that allows an appropriate proportion of growth to take place in sustainable village locations to compliment that being focused to strategic allocations.

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