Greater Cambridge Local Plan: Proposed Submission

Central Bedfordshire Council suggests that criterion 7 of policy BG/BG: Biodiversity and Geodiversity would benefit from recognising both direct and indirect impacts on biodiversity. This would ensure that all potential effects arising from development are appropriately considered and assessed.

Criterion 9 should also acknowledge sites located both within and outside the Greater Cambridge area where those sites satisfy published selection criteria. This would provide a more comprehensive and consistent approach to biodiversity protection.

In addition, criteria 9(c) and 9(d) could be strengthened by explicitly requiring developments to reflect existing landscape and river corridor characteristics, as well as protecting and enhancing important views to and from rivers.

Criterion 10 would benefit from recognising irreplaceable habitats located within adjoining local authority areas. Development proposals can have ecological effects beyond administrative boundaries, and policy wording should reflect the need to protect and enhance irreplaceable habitats both within Greater Cambridge and neighbouring authorities.

The Greensand Ridge is a distinctive “island” of significantly wooded sands and sandstone that
rises prominently above the surrounding clay vales. With a toehold in both Buckinghamshire and Cambridgeshire, and stretching over 45 km, the vast majority of the 273 km2 of this attractive landscape is in Bedfordshire. The north eastern extent runs within the area of the Draft Greater Cambridge Local Plan but has not been included within the extent of the area to be considered, protected and enhanced. It is essential that policies ensure that development within the area does not have adverse effects which would have indirect landscape and visual
effects within Central Bedfordshire.

Paragraph 5.3 refers to the Cambridgeshire and Peterborough Local Nature Recovery Strategy. Whilst support for this strategy is welcomed, consideration should also be given to neighbouring Local Nature Recovery Strategies where development proposals are located close to administrative boundaries. Cross-boundary ecological networks and habitats do not necessarily align with local authority boundaries.

Central Bedfordshire Council suggests that criterion 7 of policy BG/BG: Biodiversity and Geodiversity would benefit from recognising both direct and indirect impacts on biodiversity. This would ensure that all potential effects arising from development are appropriately considered and assessed.

Criterion 9 should also acknowledge sites located both within and outside the Greater Cambridge area where those sites satisfy published selection criteria. This would provide a more comprehensive and consistent approach to biodiversity protection. In addition, criteria 9(c) and 9(d) could be strengthened by explicitly requiring developments to reflect existing landscape and river corridor characteristics, as well as protecting and enhancing
important views to and from rivers.

Criterion 10 would benefit from recognising irreplaceable habitats located within adjoining local authority areas. Development proposals can have ecological effects beyond administrative boundaries, and policy wording should reflect the need to protect and enhance irreplaceable habitats both within Greater Cambridge and neighbouring authorities.

Criterion 2 of policy CC/RE would benefit from closer alignment with the recognised mitigation hierarchy. CBC suggest that the policy wording is amended to provide a clearer framework for managing environmental impacts associated with renewable energy development.

2. Proposals must seek to prevent, avoid or reduce adverse impacts during construction and operation, wherever possible before considering offsetting or compensation measures.

We note that the policy refers to tranquillity within criterion 1(a), however, the Greater Cambridge Landscape Sensitivity Assessment appears to focus on landscape sensitivity rather than tranquillity and views. It would be helpful to clarify whether additional evidence exists which assesses tranquillity and sensitive views, particularly where these may have implications beyond the Greater Cambridge boundary and into Central Bedfordshire.

In addition, criterion 2 of policy CC/RE would benefit from closer alignment with the recognised mitigation hierarchy. CBC suggest that the policy wording is amended to provide a clearer framework for managing environmental impacts associated with renewable energy development.

2. Proposals must seek to prevent, avoid or reduce adverse impacts during construction and operation, wherever possible before considering offsetting or compensation measures.

Central Bedfordshire Council suggests that criterion 1(a) of the policy is amended to ensure that development proposals also consider indirect adverse effects upon landscape character outside the Greater Cambridge area, as landscape character areas frequently extend beyond administrative boundaries, and development can influence the character and perception of neighbouring landscapes.

Criterion (c) would also benefit from the inclusion of the word "protect" to reinforce the importance of safeguarding landscape features before seeking to respect, conserve and enhance them.

Consideration should also be given to protecting and enhancing tranquillity both within Greater Cambridge and in adjoining local authority areas, with the supporting text strengthened by referring to how tranquillity should be assessed using existing tools such as Landscape and Visual Appraisals, Health Impact Assessments and ecological surveys.

Paragraph 7.53 would also benefit from greater emphasis being included on cross-boundary landscape considerations. Major developments, in particular, should be encouraged to consider landscape character within neighbouring authorities where relevant. The supporting text could also explicitly require Landscape and Visual Appraisals to accompany major planning applications to help ensure that landscape considerations are embedded at an early stage of the design process and that impacts on adjoining landscapes are appropriately assessed.

Central Bedfordshire Council suggests that criterion 1(a) of the policy is amended to ensure that development proposals also consider indirect adverse effects upon landscape character outside the Greater Cambridge area, as landscape character areas frequently extend beyond administrative boundaries, and development can influence the character and perception of neighbouring landscapes.

Criterion (c) would also benefit from the inclusion of the word "protect" to reinforce the importance of safeguarding landscape features before seeking to respect, conserve and enhance them.

Consideration should also be given to protecting and enhancing tranquillity both within Greater Cambridge and in adjoining local authority areas, with the supporting text strengthened by referring to how tranquillity should be assessed using existing tools such as Landscape and Visual Appraisals, Health Impact Assessments and ecological surveys.

Paragraph 7.53 would also benefit from greater emphasis being included on cross-boundary landscape considerations. Major developments, in particular, should be encouraged to consider landscape character within neighbouring authorities where relevant. The supporting text could also explicitly require Landscape and Visual Appraisals to accompany major planning applications to help ensure that landscape considerations are embedded at an early stage of the design process and that impacts on adjoining landscapes are appropriately assessed.

The supporting principles under paragraph 7.6 would benefit from the addition of the word "reflect" to strengthen the relationship between development and local landscape character. Accordingly, it is suggested that the relevant principle is amended to read: "Protect, reflect and enhance landscape character." This would place greater emphasis on ensuring new development responds positively to the distinctive qualities of the existing landscape.

Central Bedfordshire Council suggests that criterion 1(d) within the policy is expanded to acknowledge potential impacts upon adjoining Local Authority character areas. Development proposals near administrative boundaries can influence landscape and settlement character beyond Greater Cambridge. The policy would therefore benefit from explicitly recognising the need to avoid undue adverse effects on adjoining authorities' character areas while enhancing the character of Greater Cambridge.

We have provided some high-level comments below in relation to the Housing policies proposed within the Greater Cambridge Local Plan which we hope will be useful.

Whilst the policy H/AH: Affordable Housing clearly sets out affordable housing requirements, it could benefit from stronger links to Policy H/HM: Housing Mix, which contains more detailed requirements relating to dwelling size, tenure and housing mix. Without a direct reference,
users of the plan may not immediately recognise the relationship between the affordable housing requirements and the associated housing mix provisions.

Central Bedfordshire Council notes that the recently published National Planning Policy Framework has removed references to First Homes and First Homes Exception Sites. As a result, references to First Homes Exception Sites within policy H/ES: Exception Sites for Affordable Housing are no longer necessary and could be removed.

The policy could also benefit from greater clarity regarding the proportion of market housing that may be permitted on rural exception sites. Whilst it is recognised that a limited amount of market housing may be necessary to support viability, the policy could specify an upper threshold in order to maintain the primary purpose of rural exception sites as predominantly affordable housing developments.

CBC welcomes the proposed approach set out within the policy, that at the end of the 12 month marketing period there is flexibility to continue marketing for a further period or transfer such homes to a Registered Provider, to ensure homes are delivered and remain occupied.

We have provided some high-level comments below in relation to landscape across several policies proposed within the Greater Cambridge Local Plan which we hope will be useful.

To ensure consistency and robustness across the Local Plan, consideration should be given to incorporating landscape mitigation requirements within Policies J/NE, J/RE, J/VA, H/DC and H/GT where development may affect the Green Belt or wider countryside. In particular, policies should require landscaping measures that mitigate adverse landscape and visual effects whilst reflecting and respecting local landscape character. This would help ensure that development proposals contribute positively to the landscape and maintain the distinctive qualities of the surrounding environment.

We have provided some high-level comments below in relation to landscape across several policies proposed within the Greater Cambridge Local Plan which we hope will be useful.

To ensure consistency and robustness across the Local Plan, consideration should be given to incorporating landscape mitigation requirements within Policies J/NE, J/RE, J/VA, H/DC and H/GT where development may affect the Green Belt or wider countryside. In particular, policies should require landscaping measures that mitigate adverse landscape and visual effects whilst reflecting and respecting local landscape character. This would help ensure that development proposals contribute positively to the landscape and maintain the distinctive qualities of the
surrounding environment.

We have provided some high-level comments below in relation to the Housing policies proposed within the Greater Cambridge Local Plan which we hope will be useful.

This policy could benefit from extending accessibility requirements to relevant conversion schemes. Whilst it is acknowledged that some conversions may present physical constraints that limit the delivery of M4(2) or M4(3) standards, there may be instances where such standards can reasonably be achieved. Including conversions within the scope of the policy would maximise opportunities to deliver accessible accommodation and support wider housing objectives.

We have provided some high-level comments below in relation to landscape across several policies proposed within the Greater Cambridge Local Plan which we hope will be useful.

To ensure consistency and robustness across the Local Plan, consideration should be given to incorporating landscape mitigation requirements within Policies J/NE, J/RE, J/VA, H/DC and H/GT where development may affect the Green Belt or wider countryside. In particular, policies should require landscaping measures that mitigate adverse landscape and visual effects whilst reflecting and respecting local landscape character. This would help ensure that development proposals contribute positively to the landscape and maintain the distinctive qualities of the
surrounding environment.