Gamlingay Neighbourhood Plan Submission version

Object

Representation ID: 56592

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Policies Map and Maps

Concerns about clarity of maps.

Support

Representation ID: 56593

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Map 1
Map 1 shows the neighbourhood area for Gamlingay – we would recommend using a stronger map base that enable readers to find key information. In this instance, because land west of the parish boundary is in Bedfordshire, it might help if parish and district names and the district boundary were illustrated, and the boundaries clearly shown.
A Neighbourhood Plan must be clear about the area that it covers.

Support

Representation ID: 56594

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Map 4

Map 4 shows landscape settings. It would help the future user of the Plan if there were a greater distinction between the green shadings shown on the map. They look somewhat the same. The key refers to ‘examples of good design’ but does not name these two places or provide any supporting details for why these are examples of good design.

Support

Representation ID: 56595

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Map 6
Map 6 showing Village Amenities –This map is attempting to show much information across the whole parish. By having a parish wide map this has resulted in the village centre, where many of the facilities are located, at a very small scale and it is not possible to define the exact location of those facilities.

Object

Representation ID: 56596

Received: 23/11/2021

Respondent: South Cambridgeshire District Council

Chapter 3 - Our vision
With regards to Objective 1, it is not clear how the reference to ‘high environmental standards’ is defined. For the sake of clarity, it may be better for the Neighbourhood Plan to promote new development that seeks to ‘exceed the baseline policy requirements for sustainability set out in section 4 of the Local Plan, supporting the transition to net zero carbon and the move away from fossil fuels.’

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.