Stapleford & Great Shelford Neighbourhood Plan Submission Version

INTRODUCTION
We have been instructed by Cambridgeshire County Council, as landowner, to respond to the Reg.16 consultation for the submission draft Stapleford & Great Shelford Neighbourhood Plan (draft S&GSNP). Cambridgeshire County Council owns the land allocated in the adopted South Cambridgeshire Local Plan for an extension to Cambridge Biomedical Campus – Policy E/2. As set out in these representations, there are policies and designations in draft S&GSNP that are not in general conformity with and undermine this allocation, and are inconsistent with national policy.

In summary, Cambridgeshire County Council’s representations to draft S&GSNP are as follows:
• Comment on the Policy Context section of draft S&GSNP to highlight those development plan documents that are not referred to (Cambridge Southern Fringe AAP), to identify relevant emerging development plan and policy documents (emerging Greater Cambridge Local Plan and draft Cambridge Biomedical Campus SPD), and revised national policy (NPPF December 2024).
• Object to Policy S&GS 12 (Protecting and Enhancing Stapleford and Great Shelford’s Landscape Character) because it does not take into account the allocation for an extension to Cambridge Biomedical Campus in the adopted South Cambridgeshire Local Plan, or that all of the land between Stapleford and Great Shelford and Cambridge is already designated as Green Belt.
• Object to Policy S&GS 13 (Important Views) because View K (DNA Path next to bridge over railway) and View P (High point on Granhams Road) are general views of the countryside and do not contain any notable landscape features, Policy E/2 includes landscape requirements for the extension to the Biomedical Campus, and Policies NH/2 and HQ1 of the adopted South Cambridgeshire Local Plan already protect landscape character and the character of areas in the wider landscape.
• Object to Policy S&GS 21 (Delivering Stapleford and Great Shelford’s Improved Landscape Area) because it is not in general conformity with and undermines the allocation for an extension to Cambridge Biomedical Campus in Policy E/2 of the adopted South Cambridgeshire Local Plan, and the land included within this proposed designation is already identified as an area for a Countryside Enhancement Strategy under Policy CSF/5 of the adopted Cambridge Southern Fringe AAP which remains part of the development plan and should not be duplicated.

In due course draft S&GSNP will be examined by an Independent Examiner who will determine whether the basic conditions for a neighbourhood plan have been met. As explained in this response, it is considered that some of the policies and designations in draft S&GSNP do not meet Basic Condition (a) and are inconsistent with national policy, or Basic Condition (e) and are not in general conformity with the strategic policies contained in the development plan for the area.

At the end of the representations to each policy is a summary and the requested changes.

REPRESENTATIONS TO DRAFT S&GSNP

Policy Context

COMMENT

Paragraphs 3.2 to 3.5 of draft S&GSNP seeks to identify the policy context for the document. It is considered that this section covers only part of the relevant policy context, and omits references to other development plan documents, to emerging development plan and policy documents, and to national policy. This is relevant because some policies in draft S&GSNP are inconsistent with adopted and emerging development plan policies and with national policies, as set out in these representations. Those inconsistencies might not have occurred if the policy context section had provided a more comprehensive review of adopted and emerging policy.

The policy context section identifies Policy E/2 in the adopted South Cambridgeshire Local Plan for an extension to Cambridge Biomedical Campus, and refers to some of the criteria contained in the adopted policy, but not all. Criteria (e) and criteria (h) to Policy E/2, not referred to in the policy context, are relevant to the representations to Policy S&GS 21. It is noted that Map 14, which is related to Policy S&GS 21, incorrectly includes the land allocated for an extension to the Cambridge Biomedical Campus within the proposed Improved Landscape Area. The full text of Policy E2 is provided in Appendix A of these representations, and the associated Proposals Map (Inset E South of Addenbrookes) is provided in Appendix B.


The policy context section does not identify the adopted Cambridge Southern Fringe AAP as a relevant development plan document for draft S&GSNP. As set out in the representations to Policy S&GS 12 and Policy S&GS 21, the proposed Improved Landscape Area duplicates similar policies in the Cambridge Southern Fringe AAP but does not mention the important connection between countryside enhancements and development contained in the AAP.

The policy context section refers to the Green Belt and highlights the extent of the Green Belt around the villages and between the villages and Cambridge. The policy section does not refer to national policy relating to the Green Belt as contained in Chapter 13 of the NPPF. As set out in the representations to Policy S&GS 12, the adopted Local Plan and the NPPF already provide strong protection from development for land located within the Green Belt, and it is unnecessary for draft S&GSNP to include similar policies to these areas.

Paragraph 3.5 of the policy context section refers to the emerging Greater Cambridge Local Plan. The draft S&GSNP refers to a preferred allocation within the plan area. However, it does not mention the preferred allocation immediately adjacent to the northern edge of the plan area boundary adjacent to Cambridge Biomedical Campus - Policy S/CBC Cambridge Biomedical Campus (including Addenbrooke’s Hospital). The full text and plans relating to emerging Policy S/CBC are provided in Appendix C. This preferred allocation is relevant to the representations to Policy S&GS 12 and Policy S&GS 13.

Greater Cambridge Shared Planning Service has recently consulted on a draft Cambridge Biomedical Campus SPD, which has been prepared in the context of adopted Policy E/2 and emerging Policy S/CBC. The draft SPD outlines some development principles for the expansion of Cambridge Biomedical Campus, including principles for design, landscape and open space. The draft SPD is not mentioned in the policy context section of draft S&GSNP. The draft SPD is relevant to the representations to Policy S&GS 12 and Policy S&GS 13.

It is considered that a more comprehensive review of the relevant policy context for draft S&GSNP would have highlighted that some policies and designations are not required.

Summary Representation
Paragraphs 3.2 to 3.5 of draft S&GSNP provide only part of the relevant policy context. The adopted Cambridge Southern Fringe AAP should be identified as a relevant development plan document. Policy E/2 in the adopted South Cambridgeshire Local Plan, Policy S/CBC in the emerging Greater Cambridge Local Plan, and the Green Belt policy in the NPPF should be referenced in more detail. The draft Cambridge Biomedical Campus SPD should be referenced as relevant policy guidance. A more comprehensive review of the relevant policy context for draft S&GSNP would have highlighted that some policies and designations are not required.

Requested Change
It is requested that the policy context section in draft S&GSNP refers to the adopted Cambridge Southern Fringe AAP and draft Cambridge Biomedical Campus SPD, and refers to additional policy requirements from Policy E/2 in the adopted South Cambridgeshire Local Plan, Policy S/CBC in the emerging Greater Cambridge Local Plan, and Chapter 13 in the NPPF.


Policy S&GS 12: Protecting and Enhancing Stapleford and Great Shelford’s Landscape Character

OBJECT

Policy S&GS 12 relates to landscape character. Criteria 1(b) of this policy seeks to retain the existing area of separation between Stapleford and Great Shelford and the City of Cambridge. Criteria 4 of this policy refers to development affecting the proposed Landscape Improvement Area in Policy S&GS 21. In summary, these criteria do not take into account the allocation for an extension to Cambridge Biomedical Campus in the adopted South Cambridgeshire Local Plan, that all of the land between the villages and Cambridge is already designated as Green Belt, or that a Countryside Enhancement Strategy is identified in the adopted Cambridge Southern Fringe AAP.

Policy E/2 in the adopted South Cambridgeshire Local Plan allocates land for an extension to Cambridge Biomedical Campus, which is located on the edge of Cambridge and within the northern boundary of the draft S&GSNP Area. The full text of Policy E2 is provided in Appendix A of these representations, and the associated Proposals Map (Inset E South of Addenbrookes) is provided in Appendix B. Policy E/2 is a strategic policy as set out in Appendix E of the adopted Local Plan. Policy S/CBC in the emerging Greater Cambridge Local Plan identifies a preferred allocation for an additional extension to Cambridge Biomedical Campus, which is located beyond and adjacent to the northern boundary of the draft S&GSNP Area. The full text and plans relating to emerging Policy S/CBC are provided in Appendix C. No planning applications have been submitted for either the adopted or emerging allocations at Cambridge Biomedical Campus. However, these two allocations would both reduce the separation between the villages and Cambridge. Criteria 1(b) of Policy S&GSNP is not in general conformity with Policy E/2 in the adopted South Cambridgeshire Local Plan, and as such does not meet Basic Condition (e).

Policy S/4 of the adopted South Cambridgeshire Local Plan seeks to maintain a Green Belt around Cambridge, with any development proposals in the Green Belt assessed against national policies contained in the NPPF. The Green Belt at Great Shelford and Stapleford is defined on the Local Plan Proposals Map Inset No.45. As highlighted in Paragraph 142 of the NPPF, openness is identified as an essential characteristic of the Green Belt. Policy NH/2 of the adopted South Cambridgeshire Local Plan seeks to protect and enhance landscape character, and refers to National Character Areas. Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. Criteria 1(b) of Policy S&GS 12 would duplicate the openness requirement of the Green Belt designation that already applies to land between the villages and Cambridge, and landscape character is already protected by Policy NH/2 of the adopted Local Plan. It is not necessary to duplicate development plan policies and national policies, and to do so would be inconsistent with Paragraph 16(f) of the NPPF. It is considered that, criteria 1(b) of Policy S&GS 12 is not consistent with national policy, and as such would not meet Basic Condition (a).

As set out below in the representations to Policy S&GS 21, the proposed Improved Landscape Area as currently defined in Map 14 of draft S&GSNP incorrectly includes the land allocated for an extension to Cambridge Biomedical Campus in Policy E/2 of the adopted Local Plan. The proposed Improved Landscape Area designation duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP. As requested in the representations to Policy S&GS 12, the proposed Improved Landscape Area should as a minimum exclude the land allocated for an extension to Cambridge Biomedical Campus, but preferably should be deleted entirely. As set out in the representations to Policy S&GS 12, the proposed Landscape Improvement Area is not in general conformity with Policy E/2 in the adopted Local Plan and as such does not meet Basic Condition (e), and duplicates Policy CSF/5 of the adopted Cambridge Southern Fringe AAP and as such would not meet Basic Condition (a).

Summary Representation
The reference in Criteria 1(b) of Policy S&GS 12 to retain the existing area of separation between the villages and Cambridge is inconsistent with the adopted and emerging allocations for extensions to Cambridge Biomedical Campus, and is not necessary because this area is already designated as Green Belt. Criteria 1(b) should be deleted.

The proposed Improved Landscape Area, referred to in Criteria 4 of Policy S&GS 12, duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP. Criteria 4 should be deleted.

Requested Change
It is requested that criteria 1(b) and criteria 4 of Policy S&GS 12 are deleted.


Policy S&GS 13: Important Views

OBJECT

Policy S&GS 13 identifies a number of proposed important views around the villages, which are to be maintained and enhanced as part of any development proposals. Those proposed important views are listed in Policy S&GS 13, shown on Map 7, and described in Appendix 7. It is noted that the majority of land at the edge of the villages fall within a proposed important view.

Cambridgeshire County Council owns two parcels of land within the proposed important views. One parcel of land is allocated in the adopted South Cambridgeshire Local Plan for an extension to Cambridge Biomedical Campus (Policy E/2) – see plan in Appendix B. The second parcel of land is identified as a preferred allocation for an additional extension to the Campus in the emerging Greater Cambridge Local Plan (Policy S/CBC) – see plan within Appendix C. These two parcels of land fall within View K (DNA Path next to bridge over railway) and View P (High point on Granhams Road). In summary, it is considered that proposed View K and View P are general views of the countryside only, do not contain any particularly notable landscape or topographic features, and the assessment of those views does not explain why those views are important to warrant special protection. There are other adopted development plan policies that would ensure the delivery of appropriate landscaping with development.

Appendix 7 of draft S&GSNP describes the proposed important views at View K and View P, and seeks to explain why those views should be protected. The photographs of View K and View P show a typical view of the countryside at these locations, containing agricultural land, hedgerows and trees, and areas of woodland. There are no notable key landscape or topographic features within those views to identify them as particularly important or as a defining characteristic of the adjacent villages. It is noted that the viewpoints for View K and View P are not from the edge of the villages and are not in the direction of the villages. The commentary for View K and View P in Appendix 7 of draft S&GSNP and the assessment of LCA B2 (Hobsons Brook and Ninewells arable lowland) in the Stapleford & Great Shelford Landscape Character Assessment (October 2019) does not identify any key landscape features or provide the evidence to justify why these views are sufficiently important to warrant special policy protection. The commentary for LCA B2 identifies Cambridge University Hospitals and Cambridge Biomedical Campus as visually dominant features of this area. 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 explain and justify the proposed important views at View K and View P is not robust, and as such these proposed designations do not have regard to national policy and would not meet Basic Condition (a).

Policy NH/2 of the adopted South Cambridgeshire Local Plan seeks to protect landscape character and the landscape of the National Character Areas. Policy HQ1 identifies the design principles for development, which includes preserve and enhancing the character of the area and responding to the site context in the wider landscape (criteria a) and providing high quality landscape (criteria m). Policy E/2 identifies the policy requirements for the extension to Cambridge Biomedical Campus, some of which are related to protecting landscape character – the full text of Policy E/2 is provided in Appendix A. Criteria 2(a) of Policy E/2 would retain and enhance the landscape boundary at the allocation, criteria (b) would provide a landscape setting for Nine Wells Local Nature Reserve, and criteria (g) relates to building heights for the allocation. It is anticipated that similar landscaping requirements would be identified for the preferred allocation for an additional extension to Cambridge Biomedical Campus in Policy S/CBC in the emerging Greater Cambridge Local Plan. Paragraph 16(f) of the NPPF states that plans, including neighbourhood plans, should “serve a clear purpose, avoiding unnecessary duplication of policies that apply to a particular area (including policies in this Framework, where relevant)”. The landscape character around the villages, and at View K and View P, is already protected by Policy NH/2, and high quality landscaping is required for all developments by Policy HQ1 and specifically for the extension to Cambridge Biomedical Campus by Policy E/2. It is not necessary to duplicate development plan policies related to protecting landscape character, and to do so would be inconsistent with Paragraph 16(f) of the NPPF and would not meet Basic Condition (a).

It is suggested that the Neighbourhood Plan Group for draft S&GSNP review the Examiner’s Report for the Fulbourn Neighbourhood Plan (published April 2022), which also considered proposed locally important views for that document - see Paragraphs 7.33 to 7.35. In summary, the draft Fulbourn Neighbourhood Plan identified multiple viewpoints into and out of the village that should be protected. The Examiner concluded that those proposed viewpoints were general in nature, the importance of those views to the surrounding landscape was not explained, and the relationship between the views and the settlement was not identified. The Examiner recommended that all of the proposed locally important viewpoints be deleted. It is suggested that the outcome would be the same for the proposed important views identified in Policy S&GS12, including View K and View P.

It is noted that no other made neighbourhood plans in South Cambridgeshire include a policy to protect identified views. A consistent approach should be applied for all neighbourhood plans within the same district.

Summary Representation
It is considered that proposed View K and View P are general views of the countryside only, do not contain any particularly notable landscape or topographic features, and the assessment of those views does not explain why those views are important to warrant special protection. The evidence and assessment that has informed the decision to identify View K and View P is not robust. There are other adopted development plan policies that would ensure the delivery of appropriate landscaping with development. It is not necessary to duplicate other landscape development plan policies. It is requested that View K and View P are deleted.

Requested Change
It is requested that the proposed important views at View K (DNA Path next to bridge over railway) and View P (High point on Granhams Road) are deleted from Policy S&GS 13 and from Map 7, and that references to these views are removed from Appendix 7.


Policy S&GS 21: Delivering Stapleford and Great Shelford’s Improved Landscape Area

OBJECT

Policy S&GS 21 of draft S&GSNP seeks to designate all of the land on the eastern edge of Stapleford and Great Shelford as an Improved Landscape Area, for the purpose of countryside enhancement measures. The proposed Improved Landscape Area is shown on Map 14. Bullet No.8 in Paragraph 11.32 (and in the table following Paragraph 12.11) identifies a proposed area of open space adjacent to Nine Wells Local Nature Reserve (and adjacent to allocation Policy E/2). In summary, the proposed Improved Landscape Area incorrectly includes land allocated for an extension to Cambridge Biomedical Campus in the adopted South Cambridgeshire Local Plan, it refers to a new area of open space for use by Biomedical Campus employees when the allocation specifically excludes pedestrian access to adjacent areas, and it duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP.

Map 14 in draft S&GSNP identifies the extent of the proposed Improved Landscape Area and is referenced in Policy S&GS 21. Policy E/2 in the adopted South Cambridgeshire Local Plan allocates land for an extension to Cambridge Biomedical Campus. Map 14 incorrectly includes land allocated under Policy E/2 within the proposed Improved Landscape Area. The full text of Policy E/2 is provided in Appendix A of these representations, and the associated Proposals Map (Inset E South of Addenbrookes) is provided in Appendix B. Policy E/2 is identified as a strategic policy as set out in Appendix E of the adopted Local Plan. Therefore Map 14 and Policy S&GS 21 are not in general conformity with the strategic policy Policy E/2 in the adopted Local Plan, and as such do not meet Basic Condition (e). It is requested that, as a minimum, the land allocated by Policy E/2 in the adopted Local Plan is deleted from the proposed Improved Landscape Area shown on Map 14, so that Policy S&GS 21 does not apply to this land.

Bullet No.8 in Paragraph 11.32, which provides the supporting text to Policy S&GS 21, identifies a proposed area of open space adjacent to Nine Wells Local Nature Reserve for use by Biomedical Campus employees amongst others. This proposed area of open space is also referenced in the table after Paragraph 12.11. The proposed area of open space is located adjacent to allocation Policy E/2 in the adopted Local Plan. It is anticipated in Paragraphs 11.32 and 12.11 and in Policy S&GS 21 that the proposed area of open space would in part be delivered by development at Cambridge Biomedical Campus. However, criteria (e) of Policy E/2 specifically excludes pedestrian accesses from being provided on the western, southern and eastern boundaries of the allocated site, in order to minimise visitor pressure on Nine Wells Local Nature Reserve. Criteria (h) of Policy E/2 expects the proposed extension to Cambridge Biomedical Campus to include open space within the allocated site, and not elsewhere off-site. The table after Paragraph 12.11 indicates that development at Cambridge Biomedical Campus would in part be responsible for the delivery of the proposed area of open space shown on Map 14, but there is no evidence that this has been discussed or agreed with the Biomedical Campus or with the landowner Cambridgeshire County Council. Therefore, the proposed area of open space show on Map 14 and referenced in Paragraphs 11.32 and 12.11 and in Policy S&GS 21 are not in general conformity with the strategic Policy E/2 in the adopted Local Plan, and as such do not meet Basic Condition (e). It is requested that the reference to the proposed area of open space being required for Cambridge Biomedical Campus employees is deleted from Bullet No.8 in Paragraph 11.32, and that the reference to development at Cambridge Biomedical Campus being required in part to support the delivery of this open space is deleted from the table after Paragraph 12.11.

Policy CSF/5 of the adopted Cambridge Southern Fringe AAP, which is part of the adopted development plan for South Cambridgeshire, already designates the same land as the proposed Improved Landscape Area for a countryside enhancement strategy. The land designated by Policy CSF/5 is shown on Inset E of the adopted AAP. Policy CSF/5 provides additional detail of the landscape, planting and access measures required. The countryside enhancement strategy proposed in the adopted AAP are linked to and funded by development. There are no development allocations in draft S&GSNP that would support the delivery of the proposed Improved Landscape Area in Policy S&GS 20. It is considered that without an effective delivery mechanism the proposed Improved Landscape Area designation would not be implemented. Paragraph 16(f) of the NPPF states that plans, including neighbourhood 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 clear that the proposed Improved Landscape Area designation in Policy S&GS 20 duplicates Policy CSF/5 of the adopted Cambridge Southern Fringe AAP, which is not necessary. Policy S&GS 21 would be contrary to national policy, and as such would not meet Basic Condition (a). It is requested that the proposed Improved Landscape Area in Policy S&GS 21 and shown on Map 14 is deleted.

It should be noted that a green infrastructure initiative is proposed through the emerging Greater Cambridge Local Plan at Gog Magog Hills and Chalkland Fringe (see Policy BG/GI: Green Infrastructure), which is expected to carry forward the countryside enhancements strategy contained in the Cambridge Southern Fringe AAP.

Summary Representation
The proposed Improved Landscape Area incorrectly includes land allocated for an extension to Cambridge Biomedical Campus in Policy E/2 of the adopted South Cambridgeshire Local Plan. The supporting text to Policy S&GS 21 refers to a new area of open space for use by Biomedical Campus employees, when the Policy E/2 allocation specifically excludes pedestrian access to adjacent areas. The proposed Improved Landscape Area duplicates and is inconsistent with the area allocated for a Countryside Enhancement Strategy in the adopted Cambridge Southern Fringe AAP. It is requested that the proposed Improved Landscape Area in Policy S&GS 21 and shown on Map 14 is deleted.

Requested Change
It is requested that, as a minimum, the land allocated by Policy E/2 in the adopted Local Plan is deleted from the proposed Improved Landscape Area shown on Map 14, so that Policy S&GS 21 does not apply to this land.

It is requested that the reference to the proposed area of open space being required for Cambridge Biomedical Campus employees is deleted from Bullet No.8 in Paragraph 11.32, and that the reference to development at Cambridge Biomedical Campus being required in part to support the delivery of this open space is deleted from the table after Paragraph 12.11.

It is requested that the proposed Improved Landscape Area in Policy S&GS 21 and shown on Map 14 is deleted.