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Fulbourn Neighbourhood Plan - submission version

Fulbourn Neighbourhood Plan - Submission version

Representation ID: 59327

Received: 17/01/2022

Respondent: KG Moss Will Trust & Moss Family

Agent: Carter Jonas

Representation Summary:

.

Change suggested by respondent:

Requested Change
It is requested that Draft FNP is amended to include a strategy to meet the identified affordable housing needs for those with a local connection and to ensure the delivery of an extension to the recreation ground and a new multi-purpose health centre, in order to achieve Planning Objectives No.4 and No.6.

Requested Change
The following changes are requested to Figure 8.
The ‘locally important views’ designation at land off Home End (Ref. C8) is deleted.
The adopted Important Countryside Frontage designation at land off Home End is deleted.
The indicative green infrastructure network designation for land at Court Meadow House off Balsham Road is deleted.
The proposed extension to the recreation ground is deleted.

Requested Change
The following changes are requested to Policy FUL/01
It is requested that any references to adopted Important Countryside Frontages from Policy NH/13 of the adopted South Cambridgeshire Local Plan are deleted from Bullet Point No.3.
It is requested that the ‘locally important views’ designation at land off Home End (Ref. C8) is deleted from Bullet Point No.4 and from Figures 8 and 9.
It is requested that references to openness and appearance of fields that contribute to the setting of the ‘locally important views’ is deleted from Bullet Point No.5.
It is requested that reference to compliance with the Fulbourn Village Design Guide is deleted from Bullet Point No.6.

Requested Change
It is requested that Policy FUL/02 is deleted because it repeats development plan policies and national and local guidance on development outside village boundaries and design matters.

Requested Change
It is requested that, in the absence of funding or a delivery mechanism for the implementation of the indicative green infrastructure network, Policy FUL/03 and Figure 11 should be deleted
The following changes are requested to Figure 11:
The indicative green infrastructure network designation for land at Court Meadow House off Balsham Road is deleted.

Requested Change
It is requested that Section 10 is amended to include a clear commitment that all identified local affordable housing needs will be met by 2031, and to assess and allocate housing sites where affordable housing or a proportion of affordable housing can be delivered. If it is not possible to identify a sufficient amount of land to meet affordable housing needs because of policy constraints, then Section 10 should include a commitment to support the release of land from the Green Belt through the emerging Greater Cambridge Local Plan process to ensure the delivery of additional affordable housing in Fulbourn.

Requested Change
It is requested that Policy FUL/14 and the supporting text is amended to explain how the proposed extension to the recreation ground will actually be delivered, including confirmation of landowner agreement and an indication of sources of funding to enable delivery of these facilities. In the absence of any mechanism for the delivery of the extension to the recreation ground, it is requested that this site allocation is deleted from Policy FUL/14 and from Figures 8 and 19.

Requested Change
It is requested that Policy FUL/15 and the supporting text is amended to explain how the proposed multi-purpose health centre would actually be delivered, including an indication of sources of funding, potential suitable relocation sites, and potential suitable enabling residential sites. In the absence of any strategy or mechanism for the delivery of the multi-purpose health centre, it is requested that Policy FUL/15 is deleted.

Full text:

REPRESENTATIONS TO REG.16 DRAFT SUBMISSION FULBOURN NEIGHBOURHOOD PLAN

Planning Objectives
OBJECT

Paragraph 5.6 of the Draft Submission Fulbourn Neighbourhood Plan (Draft FNP) identifies the planning objectives for the document. There are two planning objectives that are relevant to these representations for the KG Moss Will Trust and the Moss Family, which are as follows: 4. Have a mix of housing that is affordable, available and suitable for all ages and appropriate to the village location; and 6. Improve amenities and community facilities.

As highlighted in the representations to Section 10: Housing, Draft FNP does not allocate any land for housing development, and the outstanding housing commitments for major development (at the Ida Darwin Hospital and land off Teversham Road sites) already define affordable housing obligations with only a small proportion specifically directed to those with a local connection to Fulbourn. As such, Draft FNP would have no influence on the delivery of affordable housing in Fulbourn because decisions about housing and affordable housing within the village have already been taken. Draft FNP does not seek to address the current identified needs for affordable housing for those with a local connection or the concerns raised by residents and employers about housing affordability. It is considered that Planning Objective No.4 is ineffective because affordable housing needs for those with a local connection will remain unmet during the plan period to 2031.

As highlighted in the representations to Policies FUL/14: Community Facilities and FUL/15: Healthcare Facilities, it is not clear whether there is landowner agreement for the proposed extension to the recreation ground, how or where the proposed new multi-purpose health centre would be provided, or where the community aspiration for additional allotments would be located. It is noted that the housing commitments at the Ida Darwin Hospital and land off Teversham Road sites already define planning obligations for health and community facilities, and include health service funding for Cherry Hinton Health Centre. Draft FNP contains no strategy to ensure the delivery or funding of these community facilities during the plan period to 2031, and as such Planning Objective No.6 is ineffective because the amenities and community facilities in the village would not be improved. Draft FNP ignores the fact that new recreation, health and community facilities are typically delivered in conjunction with new development or funded in part by planning obligations derived from new development, but does not consider this approach to deliver new or improved facilities.

Requested Change

It is requested that Draft FNP is amended to include a strategy to meet the identified affordable housing needs for those with a local connection and to ensure the delivery of an extension to the recreation ground and a new multi-purpose health centre, in order to achieve Planning Objectives No.4 and No.6.


Figure 8: Neighbourhood Plan Policy Map Summary
OBJECT

KG Moss Will Trust owns land off Home End and the Moss Family own land at Court Meadow House off Balsham Road in Fulbourn. A site location plan for each site is enclosed with these representations.
The land off Home End is included within a ‘locally important view’ (Ref. C8), and the Important Countryside Frontage designation in this location (from Policy NH/13 of the adopted South Cambridgeshire Plan) is shown on Figure 8.

Evidence Paper 1: Key Village Views, prepared to support Draft FNP, claims to provide the evidence for the ‘locally important views’ designation. However, it is noted that there are no photographs or illustrative material provided in Evidence Paper 1 to show those important views or to highlight their particular importance. The ‘view’ from land off Home End and ‘locally important view’ Ref. C8 is of buildings, a paddock, a car park, and a sport and recreation ground including cricket and football pitches, a skateboard park, bowling green, tennis courts, and multi-use games area, an equipped play area, and a sports pavilion building. The ‘view’ from this location is dominated by the sport and recreation facilities, and there are no landmarks or features that make this ‘view’ particularly important to justify special protection. The Fulbourn Village Design Statement is not supported by any landscape or visual assessments to inform the ‘key outward view from the village’ designation from the land off Home End location, and so does not provide the evidence to inform the ‘locally important view’ designations at Ref. C8 in Draft FNP. In the absence of any evidence the proposed ‘locally important view’ designation at Ref. C8 is not consistent with national guidance (see Paragraph 041 (Ref ID: 41) of the PPG) and does not meet Basic Condition (a). It is requested that the ‘locally important views’ designation at land off Home End (Ref. C8) is deleted from Figure 8.

Figure 8 shows the Important Countryside Frontage designation at land off Home End, as derived from Policy NH/13 of the adopted South Cambridgeshire Plan. Criteria (f) of Paragraph 16 in the NPPF expects development plans, including neighbourhood plans, to avoid unnecessary duplication of policies. The Important Countryside Frontage Designation at land off Home End is already identified on the Proposals Map of the South Cambridgeshire Local Plan, and therefore it is not necessary for Figure 8 in Draft FNP to replicate that designation. The inclusion of the adopted Important Countryside Frontage at land off Home End is not consistent with national policy (see Paragraph 16(f) of the NPPF) and as such does not meet Basic Condition (a). It should be noted that the made Histon & Impington Neighbourhood Plan does not refer to or repeat the important countryside frontage designations in that village; a consistent approach should be applied for all neighbourhood plans in South Cambridgeshire and all references to adopted important countryside frontages in Draft FNP should be deleted. Despite the above, it is considered that the land off Home End does not actually meet the criteria to be designated as an important countryside frontage for the following reasons. The site is surrounded by buildings and a car park. There are sport and recreation facilities and associated car parking areas between the site and the countryside beyond. The surrounding rural area is not clearly visible from the site because the sports and recreation facilities intervene, and therefore there cannot be a ‘significant connection’ between the site and the rural area. The characteristics of this site have changed significantly since the Important Countryside Frontage was first designated. It is requested that the adopted Important Countryside Frontage designation at land off Home End is deleted from Figure 8.

The land at Court Meadow House off Balsham Road is partly covered by the indicative green infrastructure network designation of Policy FUL/03 and is adjacent to a proposed extension to the recreation ground allocation of Policy FUL/15.

As set out in the representations to Policy FUL/03, the indicative green infrastructure network designations, as shown on Figure 8 do not correspond to the emerging strategic green infrastructure initiatives identified through the emerging Greater Cambridge Local Plan e.g. Strategic Green Infrastructure Initiative No.4: Enhancement of the Eastern Fens located on the eastern edge of Fulbourn. The designated nature conservation sites included in Strategic Green Infrastructure Initiative No.4 are Fulbourn Fen SSSI, Great Wilbraham Common SSSI and Wilbraham Fens SSSI. The desire in Draft FNP to connect the designated nature conservation sites with green infrastructure corridors is understood. However, it is not clear how the indicative green infrastructure network identified in Figure 8 and through Policy FUL/03 would be delivered. The focus for funding of green infrastructure projects in and around Fulbourn will be the strategic initiatives identified through the emerging Greater Cambridge Local Plan, including Strategic Green Infrastructure Initiative No.4 that coincides with designated nature conservation sites managed by local wildlife organisations. Any funding for wildlife enhancement through the environmental stewardship scheme or any similar rural initiative is outside the scope of the planning system. The planning obligations associated with the two housing commitments at Fulbourn (the Ida Darwin Hospital site and at land off Teversham Road) are already defined, including those related to green infrastructure, and as such no funding for the indicative green infrastructure network designations would be available from these developments. There are no allocations for development in Draft FNP that might support the delivery of the indicative green infrastructure network or any biodiversity net gain. It is not clear whether there has been any discussion or agreement with affected landowners about the delivery of the indicative green infrastructure network on their land; for example there has been no contact with the Moss Family in respect of the green infrastructure network proposed through land at Court Meadows House off Balsham Road. Therefore, there is no funding or delivery mechanism identified in Draft FNP for the implementation of the indicative green infrastructure network, and in the absence of such a mechanism the proposed network should be deleted from Figure 8. It is requested that the indicative green infrastructure network designation for land at Court Meadow House off Balsham Road is deleted from Figure 8. It would be possible to deliver green infrastructure in conjunction with development at land at Court Meadow House and consistent with the proposed green infrastructure network at the site e.g. a wildlife corridor alongside the existing hedgerows and bridleway, but that approach is not an option identified or supported in Draft FNP.

As set out in the representations to Policy FUL/14, it is not clear whether there is landowner agreement or funding to enable the proposed delivery of the extension to the recreation ground as identified in Figure 8. The planning obligations for local sport and recreation facilities from the two committed housing developments in Fulbourn (at the Ida Darwin Hospital site and at land off Teversham Road) are already specified in the respective s106 Agreements, and do not relate to an extension of the recreation ground. There are no other large scale developments planned or proposed within Fulbourn, and the Draft FNP makes no allocations where planning obligations could be sought to contribute towards the proposed extension to the recreation ground. Therefore, in the absence of any mechanism for the delivery of the extension to the recreation ground, it is requested that this site allocation is deleted from Figure 8. An extension to the recreation ground could be delivered in conjunction with development at land off Balsham Road, including land at Court Meadow House, but that approach is not an option identified or supported in Draft FNP.

Requested Change

The following changes are requested to Figure 8.
The ‘locally important views’ designation at land off Home End (Ref. C8) is deleted.
The adopted Important Countryside Frontage designation at land off Home End is deleted.
The indicative green infrastructure network designation for land at Court Meadow House off Balsham Road is deleted.
The proposed extension to the recreation ground is deleted.


Policy FUL/01: Protecting the Distinctiveness and Landscape Setting of Fulbourn
OBJECT

Policy FUL/01 seeks to protect the setting of Fulbourn, and refers to important countryside frontages, locally important views, and openness and appearance of fields. It also refers to the guidance provided in the Fulbourn Village Design Guide.

In summary, the Green Belt and the Development Framework boundaries in the adopted South Cambridgeshire Local Plan 2018 already limits the extent of development around the village, and severely restrict the possibility of any major new development coming forward in the future other than existing commitments which already have planning permission. It is noted that Draft FNP makes no allocations for residential or any other types of development. There are policies in the adopted Local Plan that do allow recreation facilities and rural exception affordable housing in the Green Belt. The designated village amenity areas, local green space and important countryside frontage designations in the adopted Local Plan identify areas within the Development Framework boundary of the village where additional development of all types is prevented. As explained in these representations, it is considered that Draft FNP seeks to identify additional policy designations around all parts of the village in order to prevent any major development from coming forward or being allocated through the emerging Greater Cambridge Local Plan process.

Bullet Point No.3 of Policy FUL/01 relates to Important Countryside Frontages and refers to Policy NH/13 of the adopted South Cambridgeshire Local Plan. It is not clear whether Policy FUL/01 relates to the adopted Important Countryside Frontages as defined in the Local Plan, those proposed new Important Countryside Frontages to be defined in Draft FNP, or both adopted and proposed. Figure 8 of Draft FNP includes the adopted and proposed Important Countryside Frontage designations, but Figure 9 only includes the proposed designations. Criteria (f) of Paragraph 16 of the NPPF states that plans should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. It is not necessary for Policy FUL/01 to refer to adopted Important Countryside Frontages, when a policy already exists in Policy NH/13 of the adopted South Cambridgeshire Local Plan. If Policy FUL/01 is intended to apply to adopted Important Countryside Frontage designations, then this would represent a duplication of policies and is not consistent with national guidance and so does not meet Basic Condition (a). If Policy FUL/01 does not apply to adopted Important Countryside Frontage designations then that needs to be made clear in the policy text. As set out in the representations to Figure 8: Neighbourhood Plan Policy Map Summary, the KG Moss Will Trust land off Home End does not actually meet the criteria to be designated as an important countryside frontage because the surrounding rural area is not clearly visible from the site since the sports and recreation facilities intervene.

Bullet Point No.4 of Policy FUL/01 refers to locally important views, which are identified in Figure 9. The land off Home End is included within a ‘locally important view’ (Ref. C8). Evidence Paper 1: Key Village Views, prepared to support Draft FNP, claims to provide the evidence for the ‘locally important views’ designation. However, it is noted that there are no photographs or illustrative material provided in Evidence Paper 1 to show those important views or to highlight their particular importance. The ‘view’ from land off Home End and ‘locally important view’ Ref. C8 is of buildings, a paddock, a car park, and a sport and recreation ground including cricket and football pitches, a skateboard park, bowling green, tennis courts, and multi-use games area, an equipped play area, and a sports pavilion building. The ‘view’ from this location is dominated by the sport and recreation facilities, and there are no landmarks or features that make this ‘view’ particularly important to justify special protection. The Fulbourn Village Design Statement is not supported by any landscape or visual assessments to inform the ‘key outward view from the village’ designation from the land off Home End location, and so does not provide the evidence to inform the ‘locally important view’ designations at Ref. C8 in Draft FNP. Paragraph 041 (Ref ID: 41) of the Planning Practice Guidance states that “It [neighbourhood plan policies] should be concise, precise and supported by appropriate evidence”. In the absence of any evidence the proposed ‘locally important view’ designation at Ref. C8 is not consistent with national guidance and does not meet Basic Condition (a). It is requested that the ‘locally important views’ designation at land off Home End (Ref. C8) is deleted from Policy FUL/01 and from Figures 8 and 9.

Bullet Point No.5 of Policy FUL/01 seeks to avoid adverse impacts on the openness and appearance of fields that contribute to the setting of the ‘locally important views’. The adopted South Cambridgeshire Local Plan 2018 includes policies on the Green Belt (Policy S/4) and Development Frameworks (Policy S/7). The adopted Policies Map defines the boundaries for both these designations. Policy S/4 refers to national Green Belt policy, which is set out in Section 13 of the NPPF. The principles of openness, preventing unrestricted sprawl and the coalescence of settlements, safeguarding the countryside from encroachment, and protecting the setting of settlements is already established in national Green Belt policy – see Paragraphs 137 and 138. Criteria (f) of Paragraph 16 of the NPPF states that plans should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. It is not necessary for Bullet Point No.5 of Policy FUL/01 to repeat development plan and national guidance on openness of the Green Belt or development plan policies restricting development outside village boundaries. Therefore, Policy FUL/01 is not consistent with national guidance and does not meet Basic Condition (a). It is requested that references to openness and appearance of fields that contribute to the setting of the ‘locally important views’ is deleted from Bullet Point No.5.

Bullet Point No.6 refers to the Fulbourn Village Design Guide. The Guide is adopted as a supplementary planning document, and provides design guidance for the village in the context of Policy HQ1: Design Principles of the adopted South Cambridgeshire Local Plan. Therefore, any development proposals in Fulbourn would already be assessed against Policy HQ1 and the guidance in the Fulbourn Village Design Guide. Criteria (f) of Paragraph 16 of the NPPF seeks to avoid the duplication of policies, and therefore it is not necessary for Bullet Point No.6 of Policy FUL/01 to repeat existing development plan policy and adopted guidance, and does not meet Basic Condition (a). It is requested that reference to compliance with the Fulbourn Village Design Guide is deleted from Bullet Point No.6.

Furthermore, the Fulbourn Village Design Guide was not informed by any landscape or visual evidence, and some of the terminology used in the document to describe parcels of land is not explained or robust. For example, Figure 17 of the Guide identifies the land off Home End as ‘fields with sensitive visual relationship with the village’ and as a ‘key outwards views from the village’, and the land off Balsham Road as part of a ‘key views to the village’. The land off Home End is surrounded by buildings and a car park with sport and recreation facilities beyond, and as such the site is not sensitive and it has limited physical or visual relationship with the countryside and does not represent a ‘key’ outward view from the village. The views of the village from Balsham Road are limited, and could not be described as ‘key’ views. The Fulbourn Village Design Guide does not provide the evidence to explain or justify the designations referred to in Policy FUL/01.

Requested Change

The following changes are requested to Policy FUL/01
It is requested that any references to adopted Important Countryside Frontages from Policy NH/13 of the adopted South Cambridgeshire Local Plan are deleted from Bullet Point No.3.
It is requested that the ‘locally important views’ designation at land off Home End (Ref. C8) is deleted from Bullet Point No.4 and from Figures 8 and 9.
It is requested that references to openness and appearance of fields that contribute to the setting of the ‘locally important views’ is deleted from Bullet Point No.5.
It is requested that reference to compliance with the Fulbourn Village Design Guide is deleted from Bullet Point No.6.


Policy FUL/02: Development outside the Development Framework
OBJECT

As set out in the representations to Policy FUL/01, the Green Belt and the Development Framework boundary around Fulbourn are already defined in the adopted South Cambridgeshire Local Plan, and the type and mix of uses permitted in these locations is already defined in development plan policy and national guidance. Policy HQ1 of the adopted Local Plan already adequately deals with design matters, and further guidance is provided in the National Design Guide and in Planning Practice Guidance. The Fulbourn Village Design Guide provides local guidance. Criteria (f) of Paragraph 16 of the NPPF states that plans should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. It is not necessary for Policy FUL/02 to repeat development plan policies or national and local guidance on development outside village boundaries or design matters. Therefore, Policy FUL/02 is not consistent with national guidance and does not meet Basic Condition (a).

Requested Change

It is requested that Policy FUL/02 is deleted because it repeats development plan policies and national and local guidance on development outside village boundaries and design matters.


Policy FUL/03: Creating a Connected Green Infrastructure Network
OBJECT

Policy FUL/03 seeks to deliver a green infrastructure network around Fulbourn, and Figure 11 (and Figure 8) identifies the locations for the indicative network. A large part of the land owned by the Moss Family at Court Meadow House off Balsham Road is included within the indicative green infrastructure network.

The indicative green infrastructure network designation, as shown on Figure 11 does not correspond to the emerging strategic green infrastructure initiatives identified through the emerging Greater Cambridge Local Plan – see pg. 73 to 80 of Greater Cambridge Green Infrastructure Opportunities Mapping Part 2 Recommendations Report (available at https://consultations.greatercambridgeplanning.org/sites/gcp/files/2021-09/GREATE~3_0.PDF). Strategic Green Infrastructure Initiative No.4: Enhancement of the Eastern Fens is located on the eastern edge of Fulbourn, and includes designated nature conservation sites of Fulbourn Fen SSSI, Great Wilbraham Common SSSI and Wilbraham Fens SSSI. The Part 2 Recommendations Report identifies delivery partners, a strategy and funding for Strategic Green Infrastructure Initiative No.4. The focus for the delivery and funding of green infrastructure projects around Fulbourn will be Strategic Green Infrastructure Initiative No.4 and the designated nature conservation sites managed by local wildlife organisations on the eastern edge of the village. It is not clear how the indicative green infrastructure network identified in Figure 11 and through Policy FUL/03 would be funded or delivered.
Policy FUL/03 refers to development supporting the delivery of the green infrastructure network, including new open space, wildlife areas, biodiversity net gain, and new walking/cycling routes to the countryside. However, there are no allocations for development in Draft FNP that might support the delivery of the indicative green infrastructure network or any biodiversity net gain. In the absence of any allocations for development it is not clear how the indicative green infrastructure network identified in Figure 11 would be delivered. As set out above, Strategic Green Infrastructure Initiative No.4 to be identified as part of the emerging Greater Cambridge Local Plan will be the focus for any funding on the eastern edge of Fulbourn. Any funding for wildlife enhancement through the environmental stewardship scheme or any similar rural initiative is outside the scope of the planning system.

It is not clear whether there has been any discussion or agreement with affected landowners about the delivery of the indicative green infrastructure network on their land. For example there has been no contact with the Moss Family in respect of the green infrastructure network proposed through land at Court Meadows House off Balsham Road. It is not clear how the green infrastructure network at the site would be delivered without landowner agreement and in the absence of development.

Therefore, there is no funding or delivery mechanism identified in Draft FNP for the implementation of the indicative green infrastructure network, and in the absence of such a mechanism Policy FUL/03 and Figure 11 should be deleted. It is requested that the indicative green infrastructure network designation for land at Court Meadow House off Balsham Road is deleted from Figure 11.
It would be possible to deliver green infrastructure in conjunction with development at land at Court Meadow House and consistent with the proposed green infrastructure network at the site e.g. a wildlife corridor alongside the existing hedgerows and bridleway, but that approach is not an option identified or supported in Draft FNP.

Requested Change

It is requested that, in the absence of funding or a delivery mechanism for the implementation of the indicative green infrastructure network, Policy FUL/03 and Figure 11 should be deleted
The following changes are requested to Figure 11:
The indicative green infrastructure network designation for land at Court Meadow House off Balsham Road is deleted.


Section 10: Housing
OBJECT

Section 10 of Draft FNP relates to housing, and Policy FUL/09 relates to housing developments including local housing needs. In summary, Section 10 refers to housing needs data and committed housing developments in Fulbourn. It is noted that despite the current and longstanding need for affordable housing in the village, there are no housing allocations or strategy to deliver housing or affordable housing in Draft FNP.

South Cambridgeshire District Council’s ‘Housing Statistical Information Leaflet’ (December 2019) provides the most recent information on local affordable housing needs i.e. those with a local connection to villages in the District, including Fulbourn, Teversham and Great Wilbraham – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. The current local housing needs for these three villages is as follows: Fulbourn – 65; Teversham – 21; and Great Wilbraham – 4. The Affordable Housing Needs Survey carried out by ACRE in December 2015 is out of date. The affordable housing needs of Teversham and Great Wilbraham could be met in Fulbourn, since these two villages are referred to in local connection criteria for recent affordable housing planning obligations. The current local affordable housing need should be stated as 90 dwellings. It should be noted that this current need does not take into account future needs that are likely to arise during the plan period.

Paragraph 10.3 refers to the number of dwellings to be provided at three existing housing commitments, and it is assumed that affordable housing needs would be met from these developments. However, as set out below, that is not the case. The details of the three committed housing commitments are as follows:
• App Ref. S/3396/17/FL: A rural exception housing scheme off Balsham Road for 14 affordable dwellings. The s106 Agreement includes a planning obligation requiring the affordable housing to be occupied by those that can demonstrate a local connection to Fulbourn. The development is complete.
• App Ref. S/0202/17/OL: An application for 110 dwellings off Teversham Road, with 30% affordable housing which equates to 33 affordable dwellings. The s106 Agreement includes an affordable housing obligation requiring the first 8 affordable dwellings only to be offered to those that can demonstrate a local connection, with the remainder of the affordable housing available for district-wide housing needs.
• S/0670/17/OL: An application for 203 dwellings at the former Ida Darwin Hospital site, with 40% affordable housing which equates to 81 dwellings. The s106 Agreement does not include any obligations specifying that affordable housing must be offered to those with a local connection, and therefore the affordable housing is available for district-wide needs.

Therefore, all of the Balsham Road development was available to meet local housing needs, a small proportion of the Teversham Road development will be available for local housing needs, and none of the Ida Darwin Hospital development will be specifically allocated to meet local housing needs. It is acknowledged that those with a local connection to Fulbourn, Teversham and Great Wilbraham might apply for an affordable dwelling at the Teversham Road and Ida Darwin Hospital developments, but it is likely that the majority of affordable dwellings provided at these developments will be allocated to meet district-wide housing needs. The affordable housing needs of 22 households with a local connection to Fulbourn would definitely be met from these three developments, and the affordable housing needs of some others with a local connection would probably also be met, but it is very likely that a substantial proportion of current local housing needs will remain unmet. It is inevitable that additional affordable housing needs will arise in the near future, from within Fulbourn and across the district.

As set out elsewhere in these representations, there are existing development plan policies and national designations that limit the amount of new housing that can be provided within and on the edge of Fulbourn e.g. Green Belt, Development Frameworks, Conservation Area, Listed Buildings, Local Green Space, Protected Village Amenity Area, Important Countryside Gap etc, and Draft FNP seeks to create additional restrictive policy designations e.g. ‘locally important views’. Any rural exception housing scheme is still required to address impacts on Green Belt openness and satisfy all other policy designations, and is reliant on a willing landowner to gift land for this purpose. It is likely that any redevelopment or infill development opportunities within Fulbourn would be small scale and fall below the threshold where affordable housing is required. In these circumstances, it is not clear how, where or when the current identified affordable housing needs of the village will be met, and Draft FNP takes no action to ensure that affordable housing needs are actually met. It is considered that the problems and consequences associated with not providing enough affordable housing in Fulbourn – as highlighted in Paragraphs 10.18 to 10.20 of Draft FNP - will continue for the foreseeable future.

Paragraph 8 of the NPPF identifies the three strands of sustainable development, and the social objective includes meeting housing needs. Paragraph 15 expects plans to provide a framework for addressing housing needs. Paragraph 60 sets out the Government’s objective to boost significantly the supply of housing. Paragraph 62 expects planning policies to reflect the needs for different types of housing including affordable housing. As explained above, the affordable housing needs of Fulbourn are known, but Draft FNP contains no allocations or policies to ensure the delivery of additional affordable housing. Therefore, Section 10 is inconsistent with national guidance and so does not meet Basic Condition (a), and would not achieve sustainable development because affordable housing needs would remain unmet and so does not meet Basic Condition (d).

Requested Change

It is requested that Section 10 is amended to include a clear commitment that all identified local affordable housing needs will be met by 2031, and to assess and allocate housing sites where affordable housing or a proportion of affordable housing can be delivered. If it is not possible to identify a sufficient amount of land to meet affordable housing needs because of policy constraints, then Section 10 should include a commitment to support the release of land from the Green Belt through the emerging Greater Cambridge Local Plan process to ensure the delivery of additional affordable housing in Fulbourn.


Policy FUL/14: Community Facilities
OBJECT

Policy FUL/14 allocates land for an extension to the recreation ground, which is identified on Figures 8 and 19. The rationale for seeking an extension to the recreation ground is explained in Paragraph 12.5. KG Moss and subsequently the KG Moss Will Trust previously owned parcels of land at the existing recreation ground, which were subject to compulsory purchase or private sale now being used for recreational, car parking and allotment purposes. It is noted that some improvements to community facilities will be delivered in the near future via planning obligations from the committed developments at the Ida Darwin Hospital site and at land of Teversham Road. The s106 Agreement for the Ida Darwin Hospital site includes planning obligations relating to open space and play areas to be provided on site, but there are no obligations relating to sport and recreation facilities. The s106 Agreement for the land off Teversham Road development includes a sports space contribution for the refurbishment or extension of the sports pavilion, but no obligations relating to land for sport and recreation facilities. There are no other large scale developments planned or proposed within Fulbourn, and the Draft FNP makes no allocations where planning obligations could be sought to contribute towards the proposed extension to the recreation ground.

It is not clear from Policy FUL/14 or the supporting text whether there is landowner agreement or funding to enable the delivery of the extension to the recreation ground. There should be some evidence that the land required for the proposed extension to the recreation has been discussed with the landowner and that there is at least an agreement in principle. As set out above, the two major developments in Fulbourn do not make any planning obligations towards the funding of an extension to the recreation ground. If there is no landowner agreement or source of funding to purchase the land and provide the extension to the recreation ground it is unlikely that it would be delivered, and as such will remain an aspiration only.

Paragraph 93 of the NPPF expects planning policies to support the delivery of the social, recreational and cultural facilities and services the community needs. As set out above, the delivery of the proposed extension to the recreation ground is uncertain. For this reason, Policy FUL/14 is inconsistent with national guidance and so does not meet Basic Condition (a). Therefore, in the absence of any mechanism for the delivery of the extension to the recreation ground, it is requested that this site allocation is deleted from Policy FUL/14 and from Figures 8 and 19.

An extension to the recreation ground could be delivered in conjunction with development in this location. The land owned by KG Moss Will Trust off Home End could make planning contributions towards sport and recreation facilities in the village. The land owned by the Moss Family at Court Meadow House off Balsham Road could provide planning contributions and additional land to support the delivery of the extension to the recreation ground. The option of additional development in Fulbourn providing for the extension to the recreation ground is not identified or considered in Draft FNP.

Requested Change

It is requested that Policy FUL/14 and the supporting text is amended to explain how the proposed extension to the recreation ground will actually be delivered, including confirmation of landowner agreement and an indication of sources of funding to enable delivery of these facilities. In the absence of any mechanism for the delivery of the extension to the recreation ground, it is requested that this site allocation is deleted from Policy FUL/14 and from Figures 8 and 19.


Policy FUL/15: Healthcare Facilities
OBJECT

Policy FUL/15 relates to existing and future healthcare facilities in the village, and seeks to support additional health related facilities either on the site of the existing health centre or at another location within the village. Paragraphs 12.7 and 12.8 seeks to explain the rationale for additional health facilities, and refers to enabling residential development to support the delivery of additional facilities. KG Moss previously owned the land around the current health centre and a majority of the land used for the large housing development to the north side of Cambridge Road on the Fulbourn side of Windmill Hill bounded by Haggis Gap which was subject to compulsory purchase. This development has since been redeveloped. The aspiration for a new health centre for the village has existed for a number of years.
It is noted that some improvements to community facilities will be delivered in the near future via planning obligations from the proposed developments at the Ida Darwin Hospital site and at land off Teversham Road. The s106 Agreements for both these developments include planning obligations towards the health services at Cherry Hinton Health Centre, but not for the Fulbourn Health Centre. There are no other large scale developments planned or proposed within Fulbourn, and the Draft FNP makes no allocations for residential development where planning obligations could be sought to contribute towards additional health facilities.

It is not clear whether any local health service or provider has identified a need for additional or new health facilities in Fulbourn and has a strategy to deliver such a facility; recent planning obligations have been directed to Cherry Hinton Health Centre. It is not clear whether funding is available to support the delivery of the proposed new multi-purpose health centre, either on the existing site or elsewhere within the village. If a new site is required, it is not clear whether land or a suitable site is available. There are no significant previously developed land opportunities available in the village, existing development plan policies and national designations limit development opportunities outside the village boundary e.g. Green Belt and Development Frameworks, and Draft FNP seeks to create additional restrictive policy designations e.g. ‘locally important views’. Furthermore, Draft FNP makes no allocations for residential development that might enable the delivery of a multi-purpose health centre. If there is no strategy or mechanism for the provision of a new multi-purpose health centre in the village it is unlikely that it would be delivered, and as such will remain an aspiration only.

Paragraph 93 of the NPPF expects planning policies to support the delivery of community facilities including health facilities and the delivery of health strategies. As set out above, the delivery of the proposed multi-purpose health centre is uncertain. For this reason, Policy FUL/15 is inconsistent with national guidance and so does not meet Basic Condition (a). Therefore, in the absence of any strategy or mechanism for the delivery of the multi-purpose health centre, including land for a new building or land for enabling residential development, it is requested that Policy FUL/15 is deleted.

Draft FNP does not consider the option of a multi-purpose health centre being delivered in conjunction with additional residential development. For example, if allocated for residential development the land owned by KG Moss Will Trust off Home End could make planning contributions towards additional health facilities in the village, and the land owned by the Moss Family at Court Meadow House off Balsham Road could provide land for a multi-purpose health centre as part of a mixed use development.

Requested Change

It is requested that Policy FUL/15 and the supporting text is amended to explain how the proposed multi-purpose health centre would actually be delivered, including an indication of sources of funding, potential suitable relocation sites, and potential suitable enabling residential sites. In the absence of any strategy or mechanism for the delivery of the multi-purpose health centre, it is requested that Policy FUL/15 is deleted.

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