Greater Cambridge Local Plan: Proposed Submission
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Greater Cambridge Local Plan: Proposed Submission
Policy H/GT: Gypsy and Traveller and Travelling Showpeople Plots Infrastructure
Representation ID: 212255
Received: 16/09/2026
Respondent: Cottenham Parish Council
Legally compliant? Yes
Sound? No
Unnamed strategic development sites are required make significant provision for G&T plots (also included in the existing SCDC Local Plan policy H/21.
Not all significant sites developed since the implementation of the existing SCDC Local Plan have made such provision.
If all the strategic sites included in the proposed GC Local Plan made provision as required by the policy, a large proportion of the requirement in the Accommodation Needs Assessment could be met .
Requested modifications
The Parish Council considers that the following changes are necessary:
1. The Plan should provide a clear and robust delivery trajectory for all Gypsy and Traveller pitches relied upon to meet the identified need, distinguishing between committed, deliverable, developable and merely potential provision.
2. The Plan should identify a clear contingency where strategic-site pitches are not capable of being delivered within the Plan period.
3. The evidence supporting Policy S/AMC/GT should be updated to demonstrate the actual authorised and unauthorised position at Smithy Fen.
4. The Plan should demonstrate that optimisation at Smithy Fen is capable of delivering a net improvement in health, safety, living conditions, infrastructure, drainage, flood risk and environmental quality.
5. No increase in pitch numbers should be supported at Smithy Fen unless it can first be demonstrated that the proposal is consistent with national flood-risk policy and the requirements of Policy H/GT.
6. The Plan should clearly distinguish between the regularisation/enforcement of existing provision and the creation of genuinely additional pitches through intensification.
7. The Councils should provide further evidence explaining the relationship between the 70 pitches identified as potentially becoming available through enforcement, the strategic-site provision and the need for additional optimisation at Smithy Fen.
8. The Plan should be amended where necessary to ensure that its policy wording is consistent with the current National Planning Policy Framework, noting that the former standalone Planning Policy for Traveller Sites has now been incorporated into the NPPF framework.
Representation on Policies H/GT and S/AMC/GT – Gypsy and Traveller Provision
Overall position
Cottenham Parish Council considers that the proposed approach to Gypsy and Traveller provision is not sound and, insofar as the identified deficiencies relate to the Plan's compliance with national planning policy and the statutory requirements for plan-making, is also potentially not legally compliant.
The Parish Council is not objecting to the principle of meeting the objectively assessed accommodation needs of Gypsies and Travellers. Rather, our concern is that the Plan must demonstrate that those needs will be met through a robust, deliverable, effective and sustainable strategy, based on appropriate evidence and consistent application of the Plan's own policies and national planning policy.
The Plan appears to rely substantially on a combination of:
• pitches at strategic development sites;
• the regularisation of existing pitches;
• enforcement action to recover pitches currently occupied without appropriate authorisation; and
• optimisation/intensification of existing sites, particularly Smithy Fen and Chesterton Fen.
However, there is insufficient evidence that all of these sources of supply are genuinely deliverable within the Plan period, or that the proposed optimisation of existing sites can be achieved without exacerbating existing health, safety, infrastructure, environmental and amenity problems.
This raises fundamental questions of soundness, particularly whether the Plan is positively prepared, justified and effective, and whether its policies are consistent with national planning policy.
Policy H/GT – Gypsy and Traveller pitches and Travelling Showpeople plots
1. Delivery of pitches on strategic sites
The Parish Council welcomes the principle that strategic development sites should contribute towards meeting Gypsy and Traveller accommodation needs. Policy H/GT now requires specific provision on strategic sites, with 12 pitches on strategic sites of up to 5,000 dwellings and 24 pitches on larger sites, and requires those sites to have appropriate access to services and an agreed Delivery and Management Plan.
However, the evidence supporting the Plan acknowledges that the delivery of pitches on strategic sites will depend upon the delivery of infrastructure and that not all of these pitches are anticipated to be delivered within the Plan period, with some potentially coming forward beyond 2045.
This is a significant soundness concern.
The Plan identifies 120 pitches across six strategic locations:
• Northstowe – 24
• Waterbeach New Town – 24
• Bourn Airfield New Village – 12
• Cambridge East – 24
• Cambourne – 24
• Grange Farm – 12.
The Plan should therefore clearly demonstrate:
1. which of these pitches are expected to be delivered within the Plan period;
2. when they are expected to be delivered;
3. what infrastructure dependencies could prevent their delivery;
4. how delivery will be secured through planning permissions and Section 106 agreements; and
5. what contingency exists if these pitches are delayed or are not delivered.
This is particularly important because the Plan's identified need is 159 pitches in South Cambridgeshire and 2 additional pitches in Cambridge, while the Plan's claimed supply is dependent upon several different sources, some of which are expressly described as potential rather than committed or deliverable.
The experience of the existing Local Plan also raises concerns about whether policy requirements for Gypsy and Traveller provision on major developments will necessarily translate into actual delivery.
The Plan should therefore be modified to provide a clear, evidence-based delivery mechanism and trajectory for the pitches allocated through strategic sites, together with a clear contingency where delivery is not achievable within the Plan period.
Without this, the Plan risks being ineffective, because a numerical supply which cannot realistically be delivered within the Plan period does not provide an adequate response to the identified need.
2. Relationship between strategic-site provision and optimisation of existing sites
The Plan identifies approximately 180–185 potential pitches from its various sources of supply and states that this exceeds the identified need. However, that figure includes pitches arising from enforcement, intensification and strategic sites, and the Plan acknowledges that some strategic-site provision may not come forward within the Plan period.
This makes the role and necessity of Policy S/AMC/GT particularly important.
The Plan should demonstrate, through its evidence base, why optimisation/intensification at Smithy Fen is necessary to meet the identified need, as opposed to relying upon genuinely deliverable provision at appropriately located strategic sites.
The Parish Council therefore considers that the evidence base does not adequately demonstrate that the proposed approach represents the most appropriate and sustainable strategy for meeting the identified need.
Policy S/AMC/GT – Optimisation of Gypsy and Traveller Sites
3. Lack of clarity over what "optimisation" means in practice
The Parish Council recognises the intention behind Policy S/AMC/GT to improve the health, safety, living conditions, amenities and environmental quality of existing sites.
However, there is a fundamental concern that the policy does not adequately distinguish between optimisation and intensification.
The policy permits "intensification, expansion or reconfiguration" of authorised pitches and refers to the maximum practical capacity of each site. It also states that optimisation should result in improvements to health, safety, living conditions, amenities and the environment.
However, there is insufficient evidence demonstrating:
• the existing authorised capacity of Smithy Fen;
• the existing level of occupation;
• the current physical capacity of the site;
• the number of pitches that could realistically be created;
• how overcrowding would be addressed;
• how fire safety would be improved;
• how foul drainage and other utilities would be improved;
• how flood risk would be addressed;
• how unauthorised occupation would be resolved; and
• how an increase in occupation would improve, rather than worsen, the relationship between the site and neighbouring land uses.
Without this evidence, "optimisation" risks becoming a policy mechanism for intensification without a demonstrated capacity to accommodate additional occupation safely and sustainably.
This is a significant concern in terms of justification and effectiveness.
The Plan should therefore be modified to define the circumstances in which optimisation can occur and to require demonstrable improvements to infrastructure, drainage, fire safety, flood resilience, living conditions, access and environmental quality before any increase in pitch numbers is permitted.
4. Smithy Fen – authorised and unauthorised occupation
The Parish Council is particularly concerned about the inclusion of Smithy Fen within Policy S/AMC/GT.
The Plan's evidence identifies existing pitches which are not occupied by people meeting the relevant Gypsy and Traveller definition and also identifies potential supply arising from enforcement action. The Plan estimates that enforcement action could potentially make up to 70 pitches available.
This raises an important question about whether the appropriate planning response is intensification of the site, or whether the priority should instead be the effective management and enforcement of existing planning permissions and the recovery of pitches that are not being used in accordance with those permissions.
The Parish Council considers that the Plan does not provide sufficient evidence to demonstrate that the proposed approach will resolve these existing issues.
In particular, the Plan should explain:
• the extent of authorised and unauthorised occupation at Smithy Fen;
• the number of pitches currently occupied in accordance with planning permissions;
• the number of pitches potentially recoverable through enforcement;
• the enforcement measures already undertaken;
• the reasons why those measures have not secured compliance;
• the timescale within which enforcement could realistically release additional pitches; and
• how any additional intensification would interact with existing unauthorised occupation.
Until these matters are properly evidenced, the reliance upon optimisation at Smithy Fen is not sufficiently justified.
5. Flood risk – fundamental inconsistency within the Plan
There is a particularly serious concern regarding flood risk.
The Plan's supporting text to Policy H/GT expressly states that caravans, mobile homes and park homes intended for permanent residential use are classified as "highly vulnerable" and therefore should not be permitted within Flood Zones 3a or 3b.
Smithy Fen is situated within Flood Risk Zone 3.
Therefore the Plan has a fundamental internal consistency problem: Policy S/AMC/GT specifically identifies Smithy Fen as an area for the optimisation, expansion, reconfiguration and potential intensification of Gypsy and Traveller pitches, while the Plan's own supporting text acknowledges that permanent residential traveller accommodation should not be permitted in Flood Zones 3a or 3b. The Plan must explain clearly how these two positions can be reconciled.
It is not sufficient to state that proposals will be considered against national and local flood-risk policies. If the site is subject to a fundamental national policy constraint, the Plan must demonstrate why identifying it as a specific location for optimisation is justified and deliverable.
This is a significant soundness concern and potentially raises a legal compliance issue if the Plan is not consistent with national planning policy.
The Parish Council requests that the Inspector specifically examines this matter.
6. Location, access to services and sustainability
Policy H/GT requires new pitches to be located in a sustainable location with access to a range of services and facilities, particularly a primary school and healthcare facilities. It also requires that the needs of residents can be met without placing undue pressure on existing services and facilities.
The Smithy Fen site is approximately 800m beyond the edge of the settlement, approximately 1.9km from the nearest GP surgery and approximately 2.4km from the primary school and village shops.
There is no regular public bus service serving or passing close to the site.
The Parish Council therefore questions whether the site satisfies the sustainability requirements of Policy H/GT and the national policy requirement that traveller sites should be sustainable.
The Plan's own reclassification of Cottenham from "Rural Centre" to "Minor Rural Centre" should also be considered in this context.
The Plan needs to demonstrate objectively how the existing location meets the requirements of Policy H/GT, particularly given the distance from key services and the absence of regular public transport.
7. Pressure on existing infrastructure and services
Policy H/GT requires proposals to be located where the needs of residents can be met without placing undue pressure on existing local services and facilities.
Cottenham has experienced substantial development since the adoption of the existing Local Plan, including more than 500 additional homes.
During this period, there has been no corresponding new GP provision and there is no NHS dental provision within the village. Existing infrastructure and services are therefore already under pressure.
The Parish Council is concerned that the Plan has not adequately assessed the cumulative effect of further intensification at Smithy Fen on:
• primary healthcare;
• education;
• dental provision;
• highways and transport;
• emergency services;
• drainage and sewerage;
• waste collection;
• other community infrastructure; and
• neighbouring land uses.
The Plan should contain an objective assessment of this cumulative impact rather than relying upon a general statement that optimisation will improve existing conditions.
8. Existing site conditions
The Parish Council also has concerns regarding the current physical condition and occupation of Smithy Fen.
Within the area shown on Figure 104, only approximately 50–60% of the southern plot and approximately 70% of the northern plot appears to comprise land approved for development. The remainder is understood to be subject to one or more injunctions.
The Parish Council considers that the Plan should accurately distinguish between:
• land with planning permission;
• authorised pitches;
• land subject to enforcement action or injunctions;
• land being occupied without appropriate authorisation; and
• land that could physically accommodate additional pitches.
The building outlines shown on the Plan's figure also do not appear to reflect the current extent or density of occupation.
The evidence base should therefore be updated before the Plan is adopted so that the Inspector can assess the actual baseline against which the proposed "optimisation" is being considered.
9. Health, safety, overcrowding and utilities
Policy H/GT requires proposals to provide an appropriate environment for residents in terms of health, safety and living conditions and requires essential utilities, including water, electricity, drainage and sewerage. It also expressly states that proposals must not result in overcrowding or unnecessary sprawl.
The Parish Council is concerned that some existing pitches at Smithy Fen appear to be overcrowded and that there are areas of the site where foul drainage and mains electricity are not available.
The Environment Agency has previously raised concerns regarding foul sewage disposal at permanent traveller sites in the area, including the performance of package treatment plants and the potential implications for the water environment.
Against that background, the Plan should not identify Smithy Fen for further intensification without first demonstrating that these infrastructure and environmental deficiencies can be remedied.
Indeed, increasing the number of residents before resolving existing deficiencies could reasonably be expected to increase pressure on the very infrastructure and environmental systems that the policy says should be improved.
Soundness and legal compliance
For the reasons above, Cottenham Parish Council considers that the proposed approach to Policies H/GT and S/AMC/GT has not been demonstrated to be:
• Positively prepared, because the strategy for meeting identified need relies upon a combination of potential sources of supply whose delivery within the Plan period has not been adequately demonstrated;
• Justified, because there is insufficient evidence to demonstrate why optimisation/intensification at Smithy Fen is necessary or appropriate given the availability of alternative sources of supply;
• Effective, because the Plan does not adequately demonstrate that the proposed supply can be delivered in the required timescale or that the existing constraints at Smithy Fen can be overcome; and
• Consistent with national planning policy, particularly in relation to sustainable locations, flood risk, safe and healthy living conditions and the need to identify genuinely deliverable provision.
There is also an apparent internal inconsistency within the Plan between its identification of Smithy Fen for optimisation and its recognition that permanent residential caravans and mobile homes are highly vulnerable development which should not be permitted within Flood Zones 3a or 3b.
The Parish Council therefore requests that these matters are fully examined before the Plan is found sound.
Requested modifications
The Parish Council considers that the following changes are necessary:
1. The Plan should provide a clear and robust delivery trajectory for all Gypsy and Traveller pitches relied upon to meet the identified need, distinguishing between committed, deliverable, developable and merely potential provision.
2. The Plan should identify a clear contingency where strategic-site pitches are not capable of being delivered within the Plan period.
3. The evidence supporting Policy S/AMC/GT should be updated to demonstrate the actual authorised and unauthorised position at Smithy Fen.
4. The Plan should demonstrate that optimisation at Smithy Fen is capable of delivering a net improvement in health, safety, living conditions, infrastructure, drainage, flood risk and environmental quality.
5. No increase in pitch numbers should be supported at Smithy Fen unless it can first be demonstrated that the proposal is consistent with national flood-risk policy and the requirements of Policy H/GT.
6. The Plan should clearly distinguish between the regularisation/enforcement of existing provision and the creation of genuinely additional pitches through intensification.
7. The Councils should provide further evidence explaining the relationship between the 70 pitches identified as potentially becoming available through enforcement, the strategic-site provision and the need for additional optimisation at Smithy Fen.
8. The Plan should be amended where necessary to ensure that its policy wording is consistent with the current National Planning Policy Framework, noting that the former standalone Planning Policy for Traveller Sites has now been incorporated into the NPPF framework.
Request to participate in the examination
Cottenham Parish Council wishes to participate in the examination of the Greater Cambridge Local Plan and requests the opportunity to appear before and be heard by the appointed Planning Inspector at the relevant examination hearing sessions.
In particular, the Parish Council wishes to participate in examination sessions dealing with:
• Gypsy and Traveller accommodation needs and supply;
• the soundness and effectiveness of Policies H/GT and S/AMC/GT;
• the deliverability of strategic-site Gypsy and Traveller provision;
• the evidence supporting optimisation and intensification of existing sites;
• the suitability and deliverability of Smithy Fen; and
• the consistency of the Plan's approach with national planning policy, particularly flood risk, sustainable locations, infrastructure and living conditions.
The Parish Council considers that these matters require examination of both the evidence base and the internal consistency of the submitted Plan.
We therefore request that this representation is treated as an objection seeking changes to the submitted Plan and that the Parish Council is included among those wishing to participate in the examination hearings.
Object
Greater Cambridge Local Plan: Proposed Submission
Policy S/AMC/GT: Optimisation of Gypsy and Traveller Sites
Representation ID: 212265
Received: 16/09/2026
Respondent: Cottenham Parish Council
Legally compliant? No
Sound? No
Across Greater Cambridge only Smithy and Chesterton Fen sites are detailed.
Fig104 does not take account of existing injunctions on development, which have not been publicly tested.
H/GT and NPPF require existing sites to comply with current policy, Smithy Fen does not:-
- It lies within flood zone 3 - specifically excluded in NPPF
- It is detached from required services in Cottenham (e.g. school, medical etc.) by 2km or more
- Cottenham is rated a "minor rural centre" and may not provide the required 'sustainable' location
- Areas of the site have no mains drainage or access to electricity
Requested modifications
The Parish Council considers that the following changes are necessary:
1. The Plan should provide a clear and robust delivery trajectory for all Gypsy and Traveller pitches relied upon to meet the identified need, distinguishing between committed, deliverable, developable and merely potential provision.
2. The Plan should identify a clear contingency where strategic-site pitches are not capable of being delivered within the Plan period.
3. The evidence supporting Policy S/AMC/GT should be updated to demonstrate the actual authorised and unauthorised position at Smithy Fen.
4. The Plan should demonstrate that optimisation at Smithy Fen is capable of delivering a net improvement in health, safety, living conditions, infrastructure, drainage, flood risk and environmental quality.
5. No increase in pitch numbers should be supported at Smithy Fen unless it can first be demonstrated that the proposal is consistent with national flood-risk policy and the requirements of Policy H/GT.
6. The Plan should clearly distinguish between the regularisation/enforcement of existing provision and the creation of genuinely additional pitches through intensification.
7. The Councils should provide further evidence explaining the relationship between the 70 pitches identified as potentially becoming available through enforcement, the strategic-site provision and the need for additional optimisation at Smithy Fen.
8. The Plan should be amended where necessary to ensure that its policy wording is consistent with the current National Planning Policy Framework, noting that the former standalone Planning Policy for Traveller Sites has now been incorporated into the NPPF framework.
Representation on Policies H/GT and S/AMC/GT – Gypsy and Traveller Provision
Overall position
Cottenham Parish Council considers that the proposed approach to Gypsy and Traveller provision is not sound and, insofar as the identified deficiencies relate to the Plan's compliance with national planning policy and the statutory requirements for plan-making, is also potentially not legally compliant.
The Parish Council is not objecting to the principle of meeting the objectively assessed accommodation needs of Gypsies and Travellers. Rather, our concern is that the Plan must demonstrate that those needs will be met through a robust, deliverable, effective and sustainable strategy, based on appropriate evidence and consistent application of the Plan's own policies and national planning policy.
The Plan appears to rely substantially on a combination of:
• pitches at strategic development sites;
• the regularisation of existing pitches;
• enforcement action to recover pitches currently occupied without appropriate authorisation; and
• optimisation/intensification of existing sites, particularly Smithy Fen and Chesterton Fen.
However, there is insufficient evidence that all of these sources of supply are genuinely deliverable within the Plan period, or that the proposed optimisation of existing sites can be achieved without exacerbating existing health, safety, infrastructure, environmental and amenity problems.
This raises fundamental questions of soundness, particularly whether the Plan is positively prepared, justified and effective, and whether its policies are consistent with national planning policy.
Policy H/GT – Gypsy and Traveller pitches and Travelling Showpeople plots
1. Delivery of pitches on strategic sites
The Parish Council welcomes the principle that strategic development sites should contribute towards meeting Gypsy and Traveller accommodation needs. Policy H/GT now requires specific provision on strategic sites, with 12 pitches on strategic sites of up to 5,000 dwellings and 24 pitches on larger sites, and requires those sites to have appropriate access to services and an agreed Delivery and Management Plan.
However, the evidence supporting the Plan acknowledges that the delivery of pitches on strategic sites will depend upon the delivery of infrastructure and that not all of these pitches are anticipated to be delivered within the Plan period, with some potentially coming forward beyond 2045.
This is a significant soundness concern.
The Plan identifies 120 pitches across six strategic locations:
• Northstowe – 24
• Waterbeach New Town – 24
• Bourn Airfield New Village – 12
• Cambridge East – 24
• Cambourne – 24
• Grange Farm – 12.
The Plan should therefore clearly demonstrate:
1. which of these pitches are expected to be delivered within the Plan period;
2. when they are expected to be delivered;
3. what infrastructure dependencies could prevent their delivery;
4. how delivery will be secured through planning permissions and Section 106 agreements; and
5. what contingency exists if these pitches are delayed or are not delivered.
This is particularly important because the Plan's identified need is 159 pitches in South Cambridgeshire and 2 additional pitches in Cambridge, while the Plan's claimed supply is dependent upon several different sources, some of which are expressly described as potential rather than committed or deliverable.
The experience of the existing Local Plan also raises concerns about whether policy requirements for Gypsy and Traveller provision on major developments will necessarily translate into actual delivery.
The Plan should therefore be modified to provide a clear, evidence-based delivery mechanism and trajectory for the pitches allocated through strategic sites, together with a clear contingency where delivery is not achievable within the Plan period.
Without this, the Plan risks being ineffective, because a numerical supply which cannot realistically be delivered within the Plan period does not provide an adequate response to the identified need.
2. Relationship between strategic-site provision and optimisation of existing sites
The Plan identifies approximately 180–185 potential pitches from its various sources of supply and states that this exceeds the identified need. However, that figure includes pitches arising from enforcement, intensification and strategic sites, and the Plan acknowledges that some strategic-site provision may not come forward within the Plan period.
This makes the role and necessity of Policy S/AMC/GT particularly important.
The Plan should demonstrate, through its evidence base, why optimisation/intensification at Smithy Fen is necessary to meet the identified need, as opposed to relying upon genuinely deliverable provision at appropriately located strategic sites.
The Parish Council therefore considers that the evidence base does not adequately demonstrate that the proposed approach represents the most appropriate and sustainable strategy for meeting the identified need.
Policy S/AMC/GT – Optimisation of Gypsy and Traveller Sites
3. Lack of clarity over what "optimisation" means in practice
The Parish Council recognises the intention behind Policy S/AMC/GT to improve the health, safety, living conditions, amenities and environmental quality of existing sites.
However, there is a fundamental concern that the policy does not adequately distinguish between optimisation and intensification.
The policy permits "intensification, expansion or reconfiguration" of authorised pitches and refers to the maximum practical capacity of each site. It also states that optimisation should result in improvements to health, safety, living conditions, amenities and the environment.
However, there is insufficient evidence demonstrating:
• the existing authorised capacity of Smithy Fen;
• the existing level of occupation;
• the current physical capacity of the site;
• the number of pitches that could realistically be created;
• how overcrowding would be addressed;
• how fire safety would be improved;
• how foul drainage and other utilities would be improved;
• how flood risk would be addressed;
• how unauthorised occupation would be resolved; and
• how an increase in occupation would improve, rather than worsen, the relationship between the site and neighbouring land uses.
Without this evidence, "optimisation" risks becoming a policy mechanism for intensification without a demonstrated capacity to accommodate additional occupation safely and sustainably.
This is a significant concern in terms of justification and effectiveness.
The Plan should therefore be modified to define the circumstances in which optimisation can occur and to require demonstrable improvements to infrastructure, drainage, fire safety, flood resilience, living conditions, access and environmental quality before any increase in pitch numbers is permitted.
4. Smithy Fen – authorised and unauthorised occupation
The Parish Council is particularly concerned about the inclusion of Smithy Fen within Policy S/AMC/GT.
The Plan's evidence identifies existing pitches which are not occupied by people meeting the relevant Gypsy and Traveller definition and also identifies potential supply arising from enforcement action. The Plan estimates that enforcement action could potentially make up to 70 pitches available.
This raises an important question about whether the appropriate planning response is intensification of the site, or whether the priority should instead be the effective management and enforcement of existing planning permissions and the recovery of pitches that are not being used in accordance with those permissions.
The Parish Council considers that the Plan does not provide sufficient evidence to demonstrate that the proposed approach will resolve these existing issues.
In particular, the Plan should explain:
• the extent of authorised and unauthorised occupation at Smithy Fen;
• the number of pitches currently occupied in accordance with planning permissions;
• the number of pitches potentially recoverable through enforcement;
• the enforcement measures already undertaken;
• the reasons why those measures have not secured compliance;
• the timescale within which enforcement could realistically release additional pitches; and
• how any additional intensification would interact with existing unauthorised occupation.
Until these matters are properly evidenced, the reliance upon optimisation at Smithy Fen is not sufficiently justified.
5. Flood risk – fundamental inconsistency within the Plan
There is a particularly serious concern regarding flood risk.
The Plan's supporting text to Policy H/GT expressly states that caravans, mobile homes and park homes intended for permanent residential use are classified as "highly vulnerable" and therefore should not be permitted within Flood Zones 3a or 3b.
Smithy Fen is situated within Flood Risk Zone 3.
Therefore the Plan has a fundamental internal consistency problem: Policy S/AMC/GT specifically identifies Smithy Fen as an area for the optimisation, expansion, reconfiguration and potential intensification of Gypsy and Traveller pitches, while the Plan's own supporting text acknowledges that permanent residential traveller accommodation should not be permitted in Flood Zones 3a or 3b. The Plan must explain clearly how these two positions can be reconciled.
It is not sufficient to state that proposals will be considered against national and local flood-risk policies. If the site is subject to a fundamental national policy constraint, the Plan must demonstrate why identifying it as a specific location for optimisation is justified and deliverable.
This is a significant soundness concern and potentially raises a legal compliance issue if the Plan is not consistent with national planning policy.
The Parish Council requests that the Inspector specifically examines this matter.
6. Location, access to services and sustainability
Policy H/GT requires new pitches to be located in a sustainable location with access to a range of services and facilities, particularly a primary school and healthcare facilities. It also requires that the needs of residents can be met without placing undue pressure on existing services and facilities.
The Smithy Fen site is approximately 800m beyond the edge of the settlement, approximately 1.9km from the nearest GP surgery and approximately 2.4km from the primary school and village shops.
There is no regular public bus service serving or passing close to the site.
The Parish Council therefore questions whether the site satisfies the sustainability requirements of Policy H/GT and the national policy requirement that traveller sites should be sustainable.
The Plan's own reclassification of Cottenham from "Rural Centre" to "Minor Rural Centre" should also be considered in this context.
The Plan needs to demonstrate objectively how the existing location meets the requirements of Policy H/GT, particularly given the distance from key services and the absence of regular public transport.
7. Pressure on existing infrastructure and services
Policy H/GT requires proposals to be located where the needs of residents can be met without placing undue pressure on existing local services and facilities.
Cottenham has experienced substantial development since the adoption of the existing Local Plan, including more than 500 additional homes.
During this period, there has been no corresponding new GP provision and there is no NHS dental provision within the village. Existing infrastructure and services are therefore already under pressure.
The Parish Council is concerned that the Plan has not adequately assessed the cumulative effect of further intensification at Smithy Fen on:
• primary healthcare;
• education;
• dental provision;
• highways and transport;
• emergency services;
• drainage and sewerage;
• waste collection;
• other community infrastructure; and
• neighbouring land uses.
The Plan should contain an objective assessment of this cumulative impact rather than relying upon a general statement that optimisation will improve existing conditions.
8. Existing site conditions
The Parish Council also has concerns regarding the current physical condition and occupation of Smithy Fen.
Within the area shown on Figure 104, only approximately 50–60% of the southern plot and approximately 70% of the northern plot appears to comprise land approved for development. The remainder is understood to be subject to one or more injunctions.
The Parish Council considers that the Plan should accurately distinguish between:
• land with planning permission;
• authorised pitches;
• land subject to enforcement action or injunctions;
• land being occupied without appropriate authorisation; and
• land that could physically accommodate additional pitches.
The building outlines shown on the Plan's figure also do not appear to reflect the current extent or density of occupation.
The evidence base should therefore be updated before the Plan is adopted so that the Inspector can assess the actual baseline against which the proposed "optimisation" is being considered.
9. Health, safety, overcrowding and utilities
Policy H/GT requires proposals to provide an appropriate environment for residents in terms of health, safety and living conditions and requires essential utilities, including water, electricity, drainage and sewerage. It also expressly states that proposals must not result in overcrowding or unnecessary sprawl.
The Parish Council is concerned that some existing pitches at Smithy Fen appear to be overcrowded and that there are areas of the site where foul drainage and mains electricity are not available.
The Environment Agency has previously raised concerns regarding foul sewage disposal at permanent traveller sites in the area, including the performance of package treatment plants and the potential implications for the water environment.
Against that background, the Plan should not identify Smithy Fen for further intensification without first demonstrating that these infrastructure and environmental deficiencies can be remedied.
Indeed, increasing the number of residents before resolving existing deficiencies could reasonably be expected to increase pressure on the very infrastructure and environmental systems that the policy says should be improved.
Soundness and legal compliance
For the reasons above, Cottenham Parish Council considers that the proposed approach to Policies H/GT and S/AMC/GT has not been demonstrated to be:
• Positively prepared, because the strategy for meeting identified need relies upon a combination of potential sources of supply whose delivery within the Plan period has not been adequately demonstrated;
• Justified, because there is insufficient evidence to demonstrate why optimisation/intensification at Smithy Fen is necessary or appropriate given the availability of alternative sources of supply;
• Effective, because the Plan does not adequately demonstrate that the proposed supply can be delivered in the required timescale or that the existing constraints at Smithy Fen can be overcome; and
• Consistent with national planning policy, particularly in relation to sustainable locations, flood risk, safe and healthy living conditions and the need to identify genuinely deliverable provision.
There is also an apparent internal inconsistency within the Plan between its identification of Smithy Fen for optimisation and its recognition that permanent residential caravans and mobile homes are highly vulnerable development which should not be permitted within Flood Zones 3a or 3b.
The Parish Council therefore requests that these matters are fully examined before the Plan is found sound.
