Draft Greater Cambridge Local Plan for consultation

Re- word Part 1 of the policy to:
The Councils encourage proposals for renewable and low-carbon energy generation and associated infrastructure at all scales, including domestic schemes. Proposals for development that generate energy from renewable and low-carbon sources, including associated infrastructure, grid connections and storage, will be supported, provided that any adverse impacts are addressed appropriately; including cumulative and cross- boundary impacts, on:

a. landscape, tranquillity and sensitive views, with regard to the Landscape Sensitivity Assessment. Part 2 – Renewable Energy (2021);
b. biodiversity and geodiversity, including irreplaceable habitats, protected habitats and species, and ecological networks;
c. water quality and flood risk;
d. the best and most versatile agricultural land;
e. the historic environment (including archaeological remains) and the setting of heritage assets;
f. the Green Belt;
g. aviation apparatus and air traffic safety;
h. highways safety, and the safety of active transport infrastructure and rail movements; and
i. residential amenity, including potential impacts caused by noise, vibration, dust, odour, air quality and shadow flicker.
Any adverse impacts arising from a proposal will be considered against the benefits of the scheme.

Delete Part 5 of the policy.
Part 7 of the policy would benefit from the words 'for such proposals' being inserted after 'demonstrated,'.

Policy CC/RE is not considered to be justified nor consistent with national planning policy. Paragraph 165 a) of the NPPF requires that any adverse impacts are appropriately addressed. The policy as drafted appears to suggest that planning permission will be refused where unacceptable impacts would arise. The policy should require that any such impacts are appropriately addressed. The policy would also benefit from a balancing mechanism in order to allow the benefits to be weighed against any harm.
Part 1 d of the policy, if applied literally, could be seen as restricting any such proposals on agricultural land.
Part 5 of the policy appears to be unenforceable as the decommissioning would take place at the end of the life of the planning permission.
Part 7 of the policy would benefit from the words 'for such proposals' being inserted after 'demonstrated,'.

The policy does not appear to consider a scenario where a dwelling is proposed to be demolished to enable access through to land which is being developed.

Amend part 2 to 10% net gain.

Part 2 of the policy is not justified nor compliant with national planning policy. The evidence does not suggest that a 20% net gain is necessary for major developments. It appears to be an objective of the Council but not a planning policy requirement.

Remove parts 1 and 2 of the policy.
Amend part 7 of the policy as mentioned above so that the 15 metre dimension applies to ancient woodland with a sufficient buffer provided to ancient and veteran trees etc.

Parts 1 and 2 of the policy are not justified nor consistent with national planning policy.
The requirement for tree canopy cover is not necessary (so justified) to enable the delivery of new development. There is no justification to require the delivery of such canopy cover nor is a requirement of national planning policy. Paragraph 136 of the NPPF requires, inter alia, that new streets be tree-lined.
The extent of the proposed canopy cover appears excessive in any event with almost a third (30%) of the site being the minimum requirement under Part 1. It is noted that paragraphs 5.44 and 5.46 refer to 20%. It is likely that this requirement would jeopardise the density and viability of new development.
Part 7 of the policy needs to be clearer to confirm that the 15 metre distance relates to ancient woodland only (as paragraph 5.55 suggests).

Part 6 of the policy refers to a concentration of hot food takeaways and fast food outlets.
Firstly fast food outlets are not defined in the glossary nor in the Use Classes Order.
Applying this to a food retail destination may not be appropriate given the nature of the use and destination.

Other than Part 4 the policy appears to apply to all new development as opposed to just major housing developments. This should be refined.

Amend the threshold for Part 2 of the policy from 10 to 50 dwellings.
Consider targets for Part 4 (noting the potential for cross boundary factors) or delete Part 4 and enable the matter to be agreed on a case-by-case basis.

The policy is neither justified not consistent with national planning policy. The policy is potentially discriminating towards those leaving outside of Greater Cambridgeshire.
Part 2 of the policy includes a low threshold for the submission and implementation of an Employment and Skills Plan. The threshold may lead to small and medium sized businesses having to deviate from their business plans for a development of 10 dwellings. This may deter projects from progressing.
Part 4 refers to local residents which paragraph 6.70 confirms relates to residents of Greater Cambridgeshire. It is noted that the policy does not include a specified target. Should a development site be located within say Papworth Everard then a worker within Hilton would be prejudiced as a worker in Chittering would be more favourable: despite the worker in Hilton being much closer. That seem unsustainable. Is the intention for such sites to have a lower target? The policy lacks clarity.

Question whether a. Cambourne Business Park is located within the countryside under Part 5.

Delete the policy.

The policy is not considered to be justified or consistent with national planning policy as there is no requirement in the NPPF to deliver affordable workspace. The policy is not justified and does not propose any threshold for where affordable workspace would be required to be delivered. Any threshold would require consideration in terms of practical considerations and viability.

Part 2 of the policy refers to a hierarchy of centres with three tiers being suggested. It must be noted that NPPF paragraph 91 does not require an assessment of each centre in order - it requires a sequential test where development it outside of a existing centre. As worded the policy could be construed as requiring a proposal for a small shop in a Local Centre needing to assess whether that same shop could be located within Cambridge City Centre. Clarification should be provided.