Fulbourn Neighbourhood Plan - submission version

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Fulbourn Neighbourhood Plan - submission version

Fulbourn Neighbourhood Plan - Submission version

Representation ID: 59326

Received: 17/01/2022

Respondent: Ely Diocesan Board of Finance

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, to support and not prevent additional employment development, and to ensure the delivery of an extension to the recreation ground and a new multi-purpose health centre, to achieve Planning Objectives No.4, No.5 and No.6.

Requested Change
The following changes are requested to Figure 8.
The proposed ‘important visual gap’ designation is deleted.
The ‘locally important view’ at Ref. B3 (Eastwards from Cambridge Road towards the Windmill) is deleted.
All the ‘locally’ important views’ could be deleted since they are already contained in the Fulbourn Village Design Statement.
The proposed important countryside frontage designation at Capital Park is deleted.

Requested Change
The following changes are requested to Policy FUL/01
It is requested that the proposed ‘important visual gap’ designation is deleted from Policy FUL/01 and from Figures 8 and 9.
It is requested that the proposed important countryside frontage designation around the boundary of Capital Park is deleted from Policy FUL/01 and from Figures 8 and 9.
It is requested that ‘locally important view’ at Ref. B3 (Eastwards from Cambridge Road towards the Windmill) is deleted from Bullet Point No.4 in Policy FUL/01 and from Figures 8 and 9.
All the ‘locally’ important views’, including Ref B2 (Eastwards from Shelford Road towards the south-west village edge) and Ref. C4 (Westwards from Cambridge Road towards the Windmill), could be deleted since they are already contained in the Fulbourn Village Design Statement.
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 south of Fulbourn Old Drift (adjacent to Capital Park) and land south of Cambridge Road (adjacent to Fulbourn) in the ownership of EDBF 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 enough 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/13 is deleted to avoid repeating adopted development plan policy.

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 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 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 three planning objectives that are relevant to these representations for Ely Diocesan Board of Finance (EDBF), 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; 5. Support business development and employment opportunities; 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 Policy FUL/13: Large Employment Sites, Draft FNP contains no employment allocations, and seeks to add new additional policy designations that are designed to prevent new employment development from coming forward through the emerging Greater Cambridge Local Plan process. It is considered that Draft FNP does not support business development and employment opportunities and seeks to prevent the expansion of existing employment areas including Capital Park in the future, and as such Planning Objective No.5 is ineffective.

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, to support and not prevent additional employment development, and to ensure the delivery of an extension to the recreation ground and a new multi-purpose health centre, to achieve Planning Objectives No.4, No.5 and No.6.

Figure 8: Neighbourhood Plan Policy Map Summary
OBJECT

EDBF owns land south of Fulbourn Old Drift (adjacent to Capital Park) and land south of Cambridge Road (north of Shelford Road and adjacent to Fulbourn). A site location plan showing both sites is enclosed with these representations. These sites are located within the Green Belt as defined on the Proposals Map of the adopted South Cambridgeshire Local Plan. As set out below, these sites would be directly affected by some of the proposed new policy designations within Draft FNP.

The land owned by EDBF at Fulbourn has been promoted for through the call for sites process of the emerging Greater Cambridge Local Plan for the following uses: the land south of Fulbourn Old Drift is promoted for office and research related employment development as an extension to Capital Park, with a new access and strategic landscaping; and, the eastern field at the land south of Cambridge Road is promoted for residential development including affordable housing and self/custom build plots, with a primary school, local centre, community facilities, open space and other green infrastructure.

The land south of Fulbourn Old Drift is included within the proposed ‘important visual gap’ designation, the site boundary is proposed to be defined as an important countryside gap, and a ‘locally important view’ is identified from Cambridge Road to the south of the site (Ref. B3).

The land south of Cambridge Road is within two ‘locally important views’, one from Shelford Road towards the village (Ref. B2) and another from the edge of the village on Cambridge Road (Ref. C4).

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)”. 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”. It is not necessary for Figure 8 (or Figure 9) to repeat development plan designations or national guidance on the Green Belt. There is no evidence to explain why the ‘important visual gap’ designation is necessary when the existing Green Belt designation already addresses openness and coalescence. Therefore, Figure 8 is not consistent with national guidance and does not meet Basic Condition (a). It is requested that the proposed ‘important visual gap’ designation is deleted from 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 Cambridge Road adjacent to the southern boundary of Capital Park in the direction of Fulbourn (Ref. B3) is of the main road with trees and hedgerows either side, and a substantial area of trees and vegetation to the north and agricultural fields to the south; it is noted that no part of Fulbourn village is visible from this location, and there are no landmarks or features that make this ‘view’ particularly important to justify special protection. The ‘view’ from Shelford Road towards the village (Ref. B2) includes Fulbourn Windmill and the main road, agricultural fields, and the edge of the village; it is noted that some of the housing on the edge of the village is clearly visible with no landscaping provided at the site boundary. The ‘view’ west from the edge of the village on Cambridge Road (Ref. C4) includes Fulbourn Windmill and the main road with hedgerows either side; it is noted that the Windmill is clearly visible from this location and that ‘view’ should be retained, but the edge of Cambridge and the wider countryside is not visible from this location because of the topography (Cambridge is visible from the Windmill not from the edge of the village). It should be noted that all of the ‘locally important views’ are of land within the Green Belt and outside the defined Development Framework boundary for the village. In addition, the Fulbourn Village Design Statement, which is related to Policy HQ1: Design Principles of the adopted South Cambridgeshire Local Plan, already identifies these same ‘views’. 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)”. 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”. It is not necessary for ‘locally important views’ to be identified in areas defined as Green Belt, and where development plan design policies and related guidance already deals with the protection of landscape, heritage assets, character etc. There is no evidence to justify the ‘locally important view’ at Ref. B3 (Eastwards from Cambridge Road towards the Windmill) when no part of Fulbourn village or Fulbourn Windmill is visible from this location. The Fulbourn Village Design Statement, which is adopted guidance, already identifies these same ‘views’ and it is not necessary to repeat that guidance in Draft FNP. Therefore, Figure 8 is not consistent with national guidance and does not meet Basic Condition (a). It is requested that ‘locally important view’ at Ref. B3 (Eastwards from Cambridge Road towards the Windmill) is deleted from Figure 8. All the ‘locally’ important views’ could be deleted since they are already contained in the Fulbourn Village Design Statement.

Evidence Paper 2: Important Countryside Frontages, prepared to support Draft FNP, claims to provide the evidence for the proposed new important countryside frontage designations, including at the boundary of Capital Park. Policy NH/13 of the adopted South Cambridgeshire Local Plan sets out the policy for important countryside frontages. Important countryside frontages are defined where land with a strong countryside character penetrates the urban area or where land provides an important rural break between detached parts of a development framework boundary. It is noted that the site boundary of Capital Park is not identified as an important countryside frontage in the adopted Local Plan. Capital Park is located within the Green Belt, the countryside does not penetrate the urban area in this location, and there are no defined settlement framework boundaries in this location or adjacent areas. The distance between the defined settlement framework boundaries, located on the edge of Cambridge at Yarrow Road and on the western edge of Fulbourn, is approximately 1.4km and as such are not nearby to one another. Therefore, the land south of Fulbourn Old Drift and adjacent to Capital Park does not satisfy any of the criteria for designation as an important countryside frontage. 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”. The evidence put forward to justify the proposed important countryside frontage designation at Capital Park is not robust, and is not consistent with the criteria for such a designation. It is requested that the proposed important countryside frontage designation at Capital Park is deleted from Figure 8.

Requested Change
The following changes are requested to Figure 8.

The proposed ‘important visual gap’ designation is deleted.

The ‘locally important view’ at Ref. B3 (Eastwards from Cambridge Road towards the Windmill) is deleted.

All the ‘locally’ important views’ could be deleted since they are already contained in the Fulbourn Village Design Statement.

The proposed important countryside frontage designation at Capital Park 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 an important visual gap, 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.

EDBF owns land south of Fulbourn Old Drift (adjacent to Capital Park) and land south of Cambridge Road (north of Shelford Road and adjacent to Fulbourn), which are affected by the proposed new policy designations identified in Policy FUL/01. The land south of Fulbourn Old Drift is included within the proposed ‘important visual gap’ designation, the site boundary is proposed to be defined as an important countryside gap, and a ‘locally important view’ is identified from Cambridge Road to the south of the site (Ref. B3). The land south of Cambridge Road is within two ‘locally important views’, one from Shelford Road towards the village (Ref. B2) and another from the edge of the village on Cambridge Road (Ref. C4).

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, employment 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 to prevent any major development from coming forward or being allocated through the emerging Greater Cambridge Local Plan process.

Bullet Point No.2 of Policy seeks to identify an ‘important visual gap’ designation on the edge of Cambridge, which overlaps with the existing Green Belt designation. 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)”. 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”. It is not necessary for Figure 8 (or Figure 9) to repeat development plan designations or national guidance on the Green Belt. There is no evidence to explain why the ‘important visual gap’ designation is necessary when the existing Green Belt designation already addresses openness and coalescence. Therefore, Figure 8 is not consistent with national guidance and does not meet Basic Condition (a). It is requested that the proposed ‘important visual gap’ designation is deleted from Policy FUL/01 and from Figures 8 and 9.

Bullet Point No.3 of Policy FUL/01 relates to Important Countryside Frontages, which are identified in Figures 8 and 9, and refers to Policy NH/13 of the adopted South Cambridgeshire Local Plan. Evidence Paper 2: Important Countryside Frontages claims to provide the evidence for the proposed new important countryside frontage designations, including at the boundary of Capital Park. Policy NH/13 of the adopted South Cambridgeshire Local Plan sets out the policy for important countryside frontages. Important countryside frontages are defined where land with a strong countryside character penetrates the urban area or where land provides an important rural break between detached parts of a development framework boundary. It is noted that the site boundary of Capital Park is not identified as an important countryside frontage in the adopted Local Plan. Capital Park is located within the Green Belt, the countryside does not penetrate the urban area in this location, and there are no defined settlement framework boundaries in this location or adjacent areas. The distance between the defined settlement framework boundaries, located on the edge of Cambridge at Yarrow Road and on the western edge of Fulbourn, is approximately 1.4km and as such are not nearby to one another. Therefore, the land south of Fulbourn Old Drift and adjacent to Capital Park does not satisfy any of the criteria for designation as an important countryside frontage. 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”. The evidence put forward to justify the proposed important countryside frontage designation at Capital Park is not robust, and is not consistent with the criteria for such a designation. It is requested that the proposed important countryside frontage designation around the boundary of Capital Park is deleted from Policy FUL/01 and from Figures 8 and 9.

Bullet Point No.4 of Policy FUL/01 refers to locally important views, which are identified in Figure 9. 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 Cambridge Road adjacent to the southern boundary of Capital Park in the direction of Fulbourn (Ref. B3) is of the main road with trees and hedgerows either side, and a substantial area of trees and vegetation to the north and agricultural fields to the south; it is noted that no part of Fulbourn village is visible from this location, and there are no landmarks or features that make this ‘view’ particularly important to justify special protection. The ‘view’ from Shelford Road towards the village (Ref. B2) includes Fulbourn Windmill and the main road, agricultural fields, and the edge of the village; it is noted that some of the housing on the edge of the village is clearly visible with no landscaping provided at the site boundary. The ‘view’ west from the edge of the village on Cambridge Road (Ref. C4) includes Fulbourn Windmill and the main road with hedgerows either side; it is noted that the Windmill is clearly visible from this location and that ‘view’ should be retained, but the edge of Cambridge and the wider countryside is not visible from this location because of the topography (Cambridge is visible from the Windmill not from the edge of the village). It should be noted that all of the ‘locally important views’ are of land within the Green Belt and outside the defined Development Framework boundary for the village. In addition, the Fulbourn Village Design Statement, which is related to Policy HQ1: Design Principles of the adopted South Cambridgeshire Local Plan, already identifies these same ‘views’. 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)”. 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”. It is not necessary for ‘locally important views’ to be identified in areas defined as Green Belt, and where development plan design policies and related guidance already deals with the protection of landscape, heritage assets, character etc. There is no evidence to justify the ‘locally important view’ at Ref. B3 (Eastwards from Cambridge Road towards the Windmill) when no part of Fulbourn village or Fulbourn Windmill is visible from this location. The Fulbourn Village Design Statement, which is adopted guidance, already identifies these same ‘views’ and it is not necessary to repeat that guidance in Draft FNP. Therefore, Figure 8 is not consistent with national guidance and does not meet Basic Condition (a). It is requested that ‘locally important view’ at Ref. B3 (Eastwards from Cambridge Road towards the Windmill) is deleted from Figure 8. All the ‘locally’ important views’ could be deleted since they are already contained in the Fulbourn Village Design Statement.

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 does not provide the evidence to explain or justify the ‘important visual gap’ and ‘locally important views’ designations referred to in Policy FUL/01.

Requested Change
The following changes are requested to Policy FUL/01

It is requested that the proposed ‘important visual gap’ designation is deleted from Policy FUL/01 and from Figures 8 and 9.

It is requested that the proposed important countryside frontage designation around the boundary of Capital Park is deleted from Policy FUL/01 and from Figures 8 and 9.

It is requested that ‘locally important view’ at Ref. B3 (Eastwards from Cambridge Road towards the Windmill) is deleted from Bullet Point No.4 in Policy FUL/01 and from Figures 8 and 9.

All the ‘locally’ important views’, including Ref B2 (Eastwards from Shelford Road towards the south-west village edge) and Ref. C4 (Westwards from Cambridge Road towards the Windmill), could be deleted since they are already contained in the Fulbourn Village Design Statement.

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. Parts of the land owned by EDBF at south of Fulbourn Old Drift (adjacent to Capital Park) and land south of Cambridge Road (adjacent to Fulbourn) 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 EDBF in respect of the green infrastructure network proposed for their land. 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 south of Fulbourn Old Drift (adjacent to Capital Park) and land south of Cambridge Road (adjacent to Fulbourn) in the ownership of EDBF is deleted from Figure 11.

It would be possible to deliver green infrastructure in conjunction with the developments promoted by EDBF as follows: an extension to Capital Park for office and research related employment development; and residential development of the eastern field at the land south of Cambridge Road adjacent to Fulbourn. This approach to the delivery of green infrastructure 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 south of Fulbourn Old Drift (adjacent to Capital Park) and land south of Cambridge Road (adjacent to Fulbourn) in the ownership of EDBF 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 consider 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 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 most 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 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 soon, 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 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 enough 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/13: Large Employment Sites
OBJECT

Policy FUL/13 of Draft FNP relates to large employment sites including Capital Park. EDBF is promoting an extension to Capital Park for office and research related employment through the emerging Greater Cambridge Local Plan process. Policy FUL/13 refers to existing employment policies in the adopted Local Plan and to sustainable travel outcomes for any employment development at the large employment sites. Policy E/13: New Employment Development on the Edges of Villages in the adopted South Cambridgeshire Local Plan already sets out the requirements for new employment development proposed in edge of village locations, including considering impacts on character and appearance and accessibility by walking and cycling. Policy TI/2: Planning for Sustainable Trave of the adopted Local Plan already includes requirements associated with accessibility by sustainable modes of transport and highway impacts for all types of development, including employment. Section 9 of the NPPF provides national policy to promote sustainable transport, including encouraging walking, cycling and public transport, locating development to reduce the need to travel, and avoiding severe impacts on the highway network. Criteria (f) of Paragraph 16 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)”. Policy FUL/13 serves no clear purpose, and duplicates existing Policies E/13 and TI/2 of the adopted Local Plan and Section 9 of the NPPF, and as such it is inconsistent with national guidance and so does not meet Basic Condition (a). It is requested that Policy FUL/13 is deleted to avoid repeating adopted development plan policy and national policy.

It is noted that Draft FNP contains no employment allocations, and seeks to add new additional policy designations that are designed to prevent new employment development from coming forward through the emerging Greater Cambridge Local Plan process. The proximity of Fulbourn to the employment in and on the edge of Cambridge provides an opportunity to increase travel by walking, cycling and public transport for journeys to work. There are regular bus services to Cambridge from Fulbourn, and there is a cycle route between Fulbourn and Cambridge. The Greater Cambridge Partnership has proposed a greenway (walking and cycling route) between Fulbourn and Cambridge. The Greater Cambridge Partnership’s Making Connections project seeks to improve the frequency of bus services from Fulbourn, including to Cambridge, Cambridge Station, Cambridge Biomedical Campus, and the proposed Cambridge South Station. It is considered that Draft FNP ignores the opportunity to connect housing and employment uses by sustainable modes of transport because it does not support further housing or employment development at Fulbourn. The promoted developments by EDBF at land south of Fulbourn Old Drift (for employment development) and at land south of Cambridge Road (for residential, primary school and community uses etc) could delivery additional improvements to the walking, cycling and public transport infrastructure in these locations to further encourage the use of sustainable modes of transport for travel to work.

Requested Change

It is requested that Policy FUL/13 is deleted to avoid repeating adopted development plan policy.

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. It is noted that some improvements to community facilities will be delivered soon 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.
It should be possible for an extension to the recreation ground to be delivered in conjunction with development in this location, but that is not an option that is put forward in Draft FNP. The land owned by EDBF at south of Cambridge Road could make planning contributions towards sport and recreation facilities in the village if it was allocated for a mixed use development. The promoted development by EDBF at land south of Cambridge Road also includes open space and other green infrastructure, but could also provide land for other facilities if required e.g. allotments. The option of additional development in Fulbourn providing for additional open space, allotments and other community facilities 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 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. The aspiration for a new health centre for the village has existed for several years.

It is noted that some improvements to community facilities will be delivered soon 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 EDBF south of Cambridge Road could make planning contributions towards additional health facilities in the village, or could provide land for a multi-purpose health centre in conjunction with the promoted mixed use development and local centre for the site.

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 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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