Greater Cambridge Local Plan: Proposed Submission

Hill / HE full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Barnwell Drive".

Please see Section 3: Objection to Policy BG/PO and Designation POS_0309 "Allotments at Peverel Road" and Section 4: Summary and Proposed Modification for relevant comments regarding the Policy BG/PO.

For reasons set out within the attached document, Hill / HE request the following modification to the GCLP: Amend the Policies Map and the boundary of POS_0309 "Allotments at Peverel Road" to exclude the Site. The Protected Open Space designation should be retained over the active Peverel Road allotments.

Hill / HE therefore request the following modification to the GCLP:
Amend the Policies Map and the boundary of POS_0309 “Allotments at Peverel Road” to exclude the Site. The Protected Open Space designation should be retained over the active Peverel Road allotments.

Hill / HE full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Barnwell Drive".

Please see Section 2: Site and Designation Context and Section 3: Objection to Policy BG/PO and Designation POS_309 "Allotments at Peverel Road" for relevant comments regarding the Policy BG/PO.

In summary, for reasons set out in the attached document, Hill / HE consider that the inclusion of the Site within POS_0309 "Allotments at Peverel Road" is not justified and would not provide effective basis for the application of Policy BG/PO.

The designation of land as POS should be supported by evidence demonstrating the function and importance of the land proposed for protection.
3.3 However, the evidence supporting the designation of the Site does not assess it as a separate parcel. The Open Space and Recreation Strategy 2011 assessed the Site together with the adjoining Peverel Road allotments as Site A26, “Peverel Road Allotments”. The combined area was found to have environmental and recreational importance and was assigned a quality score of 58.33%. However, the assessment did not distinguish between the characteristics and functions of the active allotments and those of the Site.
3.4 This approach is repeated in the Protected Open Spaces Review 2026. The Review identifies the combined area as POS_0309 “Allotments at Peverel Road” and classifies the whole designation as a “Food Growing Space”. It does not separately assess whether the Site itself performs a food-growing, environmental or recreational function.
3.5 The 2026 Review explains that protected open space typologies, other than informal open space, contain clearly identifiable features which allow them to be identified as falling within a particular typology without further justification. This approach assumes that the entirety of POS_0309 displays the defining characteristics of a food-growing space. That assumption is not appropriate in relation to the Site, which is not in allotment or food-growing use and is physically and functionally separate from the active allotments. This was accepted by the Council in the officer report associated with application Ref No: 16/1566/FUL. By assessing the two parcels together, the evidence base attributes the established food-growing and recreational functions of the Peverel Road allotments to the Site. It does not identify which, if any, of the characteristics recorded for the wider designation are attributable to the Site itself.
3.7 Hill / HE do not dispute that the active allotments perform an established food-growing and recreational function or that their continued protection is appropriate. However, the combined assessment does not provide proportionate, site-specific justification for extending POS_0309 across separate land that does not perform the same function. The inclusion of the Site within the designation is therefore not justified.

For the reasons set out in these representations, Hill / HE consider that the inclusion of the Site within POS_0309 “Allotments at Peverel Road” is not justified and would not provide an effective basis for the application of Policy BG/PO.
4.2 The evidence base does not assess the Site separately from the adjoining Peverel Road allotments. Instead, the two parcels have been assessed as a single area and the established food-growing and recreational functions of the active allotments have consequently been attributed to the Site. The evidence does not demonstrate that the Site itself performs an environmental or recreational function sufficient to justify its designation as Protected Open Space.
4.3 The designation is therefore not justified by proportionate, site-specific evidence. In particular, the identification of the wider area as a “Food Growing Space” does not accurately reflect the use or function of the Site, which is a) not publicly accessible; b) not in active allotment or food-growing use; and c) is physically and functionally separate from the adjoining allotments.
4.4 The position is reinforced by the planning history of the Site where the Council previously consented its redevelopment for employment purposes, recognising that the Site did not contain any allotments and any aspiration for the creation of new allotments on the Site were unrealistic.
4.5 Overall, retaining the Site within POS_0309 undermines Policy BG/PO, rendering the policy unsound, as it is not ‘justified’ or ‘effective’.
4.6 Removing the Site from POS_0309 would not prejudice the continued protection or operation of the Peverel Road allotments. The active allotments would remain designated as Protected Open Space and would continue to perform their established food-growing and recreational function. No active allotment plots or operational land would be removed from the designation.
4.7 Hill / HE therefore request the following modification to the GCLP:
Amend the Policies Map and the boundary of POS_0309 “Allotments at Peverel Road” to exclude the Site. The Protected Open Space designation should be retained over the active Peverel Road allotments.
4.8 Hill / HE consider the Site capable of delivering a high-quality residential development and are actively exploring the potential for a 100% affordable housing scheme. In the context of acute affordable housing need across Greater Cambridge, the retention of an unjustified POS designation would prevent the delivery of significant public benefits.

Hill / HE full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Barnwell Drive".

Please see Section 3: Objection to Policy BG/PO and Designation POS_0309 "Allotments at Peverel Road" and Section 4: Summary and Proposed Modification for relevant comments regarding the Policy Map.

For reasons set out within the attached document, Hill / HE request the following modification to the GCLP: Amend the Policies Map and the boundary of POS_0309 "Allotments at Peverel Road" to exclude the Site. The Protected Open Space designation should be retained over the active Peverel Road allotments.

Hill / HE full representations are set out within the attached document named: "GCLP Reg 19 Consultation Representations - Barnwell Drive".

Please see Section 2: Site and Designation Context and Section 3: Objection to Policy BG/PO and Designation POS_309 "Allotments at Peverel Road" for relevant comments regarding the Policy Map.

In summary, for reasons set out in the attached document, Hill / HE consider that the inclusion of the Site within POS_0309 "Allotments at Peverel Road" is not justified and would not provide effective basis for the application of Policy BG/PO.