Greater Cambridge Local Plan: Proposed Submission

Requested Change

It is requested that a site visit of the land at Home End is undertaken by the Policy Team at Greater Cambridge Shared Planning Service to reconsider the proposed Important Countryside Frontage designation at this location.

It is considered that the land at Home End in Fulbourn does not meet the definition of an Important Countryside Frontage, and it is requested that this designation is deleted from this site.

Policy GP/LC: Protection and Enhancement of Landscape Character

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

Policy GP/LC of draft GCLP seeks to protect and enhance local landscape character, and refers to Important Countryside Frontages that are identified as land in villages with a strong countryside character. There are two criteria for defining Important Countryside Frontages, which are land that “penetrates or sweeps into the built-up area providing a significant connection between the built environment and the surrounding rural area” or that “provides an important rural break between two nearby but detached parts of a development framework”. The Important Countryside Frontages are identified on the Proposals Maps for draft GCLP.

KG Moss Will Trust has promoted land at Home End in Fulbourn for residential development. The frontage of this site is identified as an Important Countryside Frontage in draft GCLP. KG Moss Will Trust objects to this designation.

It is considered that the land off Home End does not meet the definition of Important Countryside Frontage. The development framework is not detached in this location, and the neighbouring buildings to the south and west fall within the framework boundary, and as such the ‘important rural break’ criteria (criteria g in Policy GP/LC) is not applicable. The land off Home End is surrounded by buildings and a car park. The site is surrounded by trees and hedgerows. There are sport and recreation facilities and associated car parking areas between the site and the countryside beyond. The sport and recreation facilities include a skateboard park, bowling green (surrounded by a hedge), tennis courts (with a fence), and multi-use games area (with a fence), an equipped play area, and a sports pavilion building. The surrounding rural area is not clearly visible from the site because the sports and recreation facilities intervene. Therefore, there cannot be a connection between the site and the rural area. The site does not meet the ‘significant connection between the built environment and the surrounding rural area’ criteria (criteria f in Policy GP/LC).

The characteristics of this site have changed significantly since the Important Countryside Frontage was first designated but the designation has never been subject to review. The site does not provide a ‘significant’ connection between the street scene and surrounding rural area, and therefore the Important Countryside Frontage Designation should be deleted from the land off Home End in Fulbourn.

It is considered that a suitably designed development could be delivered at land off Home End in Fulbourn, that retains the character of the site frontage, protects the setting of heritage assets, and provides additional landscaping at the site boundary. This approach would allow for some small-scale growth at Fulbourn to meet housing and identified affordable housing needs.

In addition, as set out in the request for an addition allocation in Policy S/RRA, the land off Home End does not meet the purposes for including land in the Green Belt and should be removed from the Green Belt.

It is considered that the decision to designate land off Home End as an Important Countryside Frontage is not sound, in that is not justified and is not consistent with national policy in terms of being supported by robust evidence (NPPF Paragraph 32).

Requested Change

It is requested that a site visit of the land at Home End is undertaken by the Policy Team at Greater Cambridge Shared Planning Service to reconsider the proposed Important Countryside Frontage designation at this location.

It is considered that the land at Home End in Fulbourn does not meet the definition of an Important Countryside Frontage, and it is requested that this designation is deleted from this site.

Policy I/ST: Sustainable Transport and Connectivity

COMMENT

Policy I/ST of draft GCLP seeks to ensure that development promotes sustainable transport in order to reduce reliance on the car. Paragraph 110 of the NPPF expects the planning system to actively manage patterns of growth to support transport objectives. It is expected that significant development would be focused on locations which are or can be made sustainable, by limiting the need to travel and offering a genuine choice of transport modes. Paragraph 115 identifies factors that should be considered when assessing sites to be allocated for development, including that sustainable transport modes are prioritised, safe and suitable access can be provided, and the impacts on the transport network and highway safety can be mitigated. Policy I/ST is broadly consistent with this national policy.

KG Moss Will Trust and the Moss Family have promoted two sites in Fulbourn. The principle of directing development to locations that are accessible by sustainable modes of transport is supported, but land should be allocated in the more sustainable villages including Fulbourn to implement this approach. There are regular bus services to Cambridge, Haverhill, and Newmarket from Fulbourn, and there is a cycle route between Fulbourn and Cambridge. The Greater Cambridge Partnership is delivering a greenway (walking and cycling route) between Fulbourn and Cambridge. Fulbourn is accessible by sustainable modes of transport to the services and facilities and employment opportunities in and on the edge of Cambridge. Fulbourn is a sustainable location in transport terms, and additional development in this location would be consistent with Policy I/ST of draft GCLP and with national policy.

As set out elsewhere in these representations, amendments should be made to the development strategy for draft GCLP to direct development to the more sustainable villages including Fulbourn.

Requested Change

The following changes are requested.

The principle of identifying a housing requirement for neighbourhood plan areas should be retained in draft GCLP.

The delivery mechanism for identified housing requirements for neighbourhood plan areas should be clearly explained in Policy S/JH and Appendix C.

It is requested that draft GCLP includes a new policy to deal with the potential scenario where a neighbourhood plan is not updated or does not allocate land to meet the identified housing requirement identified in Appendix C. The new policy should support additional housing in circumstances where a neighbourhood is not updated or does not allocate land for housing. This requested change would ensure that the identified housing requirement for villages are met during the plan period.

It is requested that draft GCLP includes a policy requirement that allows relevant neighbourhood plans to release land from the Green Belt to meet the identified housing requirement for villages.

It is requested that the identified housing requirements in Appendix C include an adjustment so that affordable housing needs of villages are met during the plan period. The housing requirement for Fulbourn should be subject to an upward adjustment so that the affordable housing needs of the village are met.

Appendix C - Housing Requirements for Neighbourhood Areas within Greater Cambridge

NOT SOUND – NOT JUSTIFIED AND NOT CONSISTENT WITH NATIONAL POLICY

OBJECT

Appendix C of draft GCLP identifies a housing requirement for the period 2025 to 2045 for those designated neighbourhood plan areas. KG Moss Will Trust and the Moss Family have promoted two sites in Fulbourn. There is a recently made Fulbourn Neighbourhood Plan (made March 2023), which makes no allocations for housing. Fulbourn is surrounded by land designated as Green Belt. The Fulbourn Neighbourhood Plan could not release land from the Green Belt for development because there is no policy in the adopted South Cambridgeshire Local Plan 2018 that would have allowed this to happen.

Appendix C is related to Policy S/JH, but there is no clear mechanism as to how those identified housing requirements for neighbourhood plan areas would be delivered.

The housing requirement for Fulbourn in Appendix C is 101 dwellings between 2025 and 2045. It is positive that a housing requirement is identified for Fulbourn, but it is considered that additional policy support is required in draft GCLP to ensure that the additional housing is actually delivered in Fulbourn during the plan period. It is suggested that the housing requirement for neighbourhood plan areas should take into account the affordable housing needs of a village.

The Fulbourn Neighbourhood Plan was made in March 2023. It does not allocate any land for development. It was not able to release land from the Green Belt because the adopted South Cambridgeshire Local Plan 2018 does not include a policy that would have allowed that to happen. It is noted that Paragraph 104 (Id.41: Neighbourhood Planning) of the Planning Practice Guidance indicates that any housing requirement provided for a neighbourhood plan is not binding, and it is for the neighbourhood plan group to decide the scope of the document and whether to allocate land for development. It is also noted that the Government is no longer providing funding support for neighbourhood plans. In these circumstances, it is very unlikely that the Fulbourn Neighbourhood Plan will be updated to address the housing requirement identified in Appendix C for the village. There is no policy in draft GCLP that would ensure the identified housing requirement for Fulbourn is delivered during the plan period if the Fulbourn Neighbourhood Plan is not updated. A new policy is requested to deal with this potential scenario, in order to ensure that the identified housing requirement for Fulbourn is delivered during the plan period.

Fulbourn is surrounded by the Green Belt, and there is limited capacity within the settlement to meet the identified housing requirement for Fulbourn. It is considered that the only realistic option for meeting that identified housing requirement is for land on edge of the village to be released for development. Paragraph 145 of the NPPF states in part that “Strategic policies should establish the need for any changes to Green Belt boundaries, having regard to their intended permanence in the long term, so they can endure beyond the plan period. Where a need for changes to Green Belt boundaries has been established through strategic policies, detailed amendments to those boundaries may be made through non-strategic policies, including neighbourhood plans”. There is no policy in draft GCLP that would allow an updated Fulbourn Neighbourhood Plan to release land from the Green Belt to meet the identified housing requirement for Fulbourn. As set out above, it is very unlikely that the Fulbourn Neighbourhood Plan would be updated. As set out elsewhere in these representations, allocations should be made in Fulbourn through draft GCLP to meet the identified housing requirement for the village. KG Moss Will Trust and the Moss Family have promoted two sites in Fulbourn.

Appendix C explains how the housing requirement for neighbourhood plan areas has been calculated. In summary the housing requirement is based on the overall housing target for draft GCLP divided proportionately to each neighbourhood plan area according to the size of their population. It is considered that an adjustment should be made to the housing requirement to reflect the affordable housing needs of villages. For example, South Cambridgeshire District Council’s ‘Housing Statistical Information Sheet for 2022 (published September 2022) identified an affordable housing need of 91 dwellings for those with a local connection to Fulbourn. There are additional affordable housing needs in the neighbouring villages of Teversham and Great Wilbraham/Little Wilbraham that could be met within Fulbourn, as the larger and more sustainable village. It is requested that the housing requirement for Fulbourn seeks to also meet identified affordable housing needs. The promoted developments by KG Moss Will Trust and the Moss Family in Fulbourn would include housing and affordable housing to meet local needs of the village.

It is considered that the housing requirement figure for Fulbourn in Appendix C is not sound, in that the proposed approach is not justified as an appropriate strategy, and is not consistent with national policy in terms of not being deliverable (NPPF Paragraph 16b) and not meeting local housing needs (NPPF Paragraphs 61 and 82).

Requested Change

The following changes are requested.

The principle of identifying a housing requirement for neighbourhood plan areas should be retained in draft GCLP.

The delivery mechanism for identified housing requirements for neighbourhood plan areas should be clearly explained in Policy S/JH and Appendix C.

It is requested that draft GCLP includes a new policy to deal with the potential scenario where a neighbourhood plan is not updated or does not allocate land to meet the identified housing requirement identified in Appendix C. The new policy should support additional housing in circumstances where a neighbourhood is not updated or does not allocate land for housing. This requested change would ensure that the identified housing requirement for villages are met during the plan period.

It is requested that draft GCLP includes a policy requirement that allows relevant neighbourhood plans to release land from the Green Belt to meet the identified housing requirement for villages.

It is requested that the identified housing requirements in Appendix C include an adjustment so that affordable housing needs of villages are met during the plan period. The housing requirement for Fulbourn should be subject to an upward adjustment so that the affordable housing needs of the village are met.