Greater Cambridge Local Plan Issues & Options 2020

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Form ID: 45380
Respondent: Sharp Family
Agent: Carter Jonas

The land at xx was promoted to the call for sites process in March 2019 on behalf of xx. The representations to the Issues & Options consultation document will refer to that promoted site where relevant. Natural Cambridgeshire’s Developing with Nature Toolkit seeks to achieve a net gain in biodiversity through new development. It is agreed that development can deliver significant biodiversity enhancements. It is suggested that in deciding which sites to allocate for development in the emerging GCLP assesses not only whether the potential impacts on protected species and habitats can be mitigated but also whether development can deliver biodiversity enhancements. The promoted development at land at xx would retain any ecological features on site and seek to provide ecological enhancements, and the existing trees and hedges at the site boundary could provide the opportunity for enhancements.

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Form ID: 45381
Respondent: Sharp Family
Agent: Carter Jonas

It is considered that meeting housing and affordable housing needs is part of the well-being and social inclusion theme because housing falls within the social objective of sustainable development (as set out in Paragraph 8 of the NPPF). There are substantial affordability issues in Greater Cambridge associated with the high cost of buying and renting housing, and those that cannot afford to live in Cambridge or South Cambridgeshire close to employment opportunities having to endure longer commuting. Paragraph 8 and Chapter 8 of the NPPF identifies the other factors that relate to the wellbeing and social inclusion theme, which are about creating well-designed and safe developments, providing access to services and facilities, and providing open space. It is suggested that to achieve ‘good growth’ the emerging GCLP will need to allocate suitable sites that deliver housing and affordable housing, are accessible to services and facilities, include open space and recreation facilities. The promoted development at land at Park Lane in Dry Drayton includes housing, affordable housing, and self-build plots. The promoted development would support the existing services and facilities within Dry Drayton.

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Form ID: 45382
Respondent: Sharp Family
Agent: Carter Jonas

Section 4.3.3 of the Issues & Options consultation document identifies the factors that are relevant to the creation of safe and inclusive communities. As set out in the response to Question 16, there are substantial affordability issues in Greater Cambridge associated with the high cost of buying and renting housing, and those that cannot afford to live in Cambridge or South Cambridgeshire close to employment opportunities having to endure longer commuting. It is considered that the emerging GCLP should include a development strategy that seeks to meet housing and affordable housing needs and locate housing closer to employment opportunities to reduce in-commuting.

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Form ID: 45383
Respondent: Sharp Family
Agent: Carter Jonas

Paragraph 91 of the NPPF seeks to deliver healthy, inclusive and safe places, and identifies a number of approaches to support healthy lifestyles. It promotes social interaction through mixed-use developments, strong neighbourhood centres, street layouts that include pedestrian and cycle connections, and active street frontages for example. It enables and supports healthy lifestyles, by providing green infrastructure, sports facilities, local shops, access to healthier food, allotments, and layouts that encourage walking and cycling for example. NHS England Healthy Towns Initiatives identified ten principles to deliver healthy places, which relate to the provision of health services, meeting local and community health needs, and development design matters. In terms of design matters it is suggested that compact neighbourhoods, active travel, healthy eating opportunities, play and leisure facilities would contribute towards the delivery of healthy places. The promoted development at Land at Park Lane in Dry Drayton would be consistent with guidance and initiatives to support healthy lifestyles. The promoted development would include open space. It accessible to the services and facilities in Dry Drayton by walking and cycling. It would be well-related to the walking and cycling improvements on Madingley Road proposed by the Greater Cambridge Partnership.

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Form ID: 45384
Respondent: Sharp Family
Agent: Carter Jonas

The emerging GCLP will need to be consistent with national guidance on meeting housing needs. Paragraph 59 of the NPPF confirms the Government’s objective to significantly boost the supply of housing, and to achieve this by ensuring that a sufficient amount and variety of land for housing is identified. Paragraph 60 expects the standard method to be used to determine the minimum number of houses needed. Paragraph 61 expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Paragraph 010 of Id.2a makes it clear that the standard method is the minimum starting point for determining local housing needs, and acknowledges that there may be circumstances where actual housing need is higher than the standard method indicates. As set out in Paragraph 010 the circumstances where increases to housing need that exceed past trends are as follows: there is a growth strategy in place to promote and facilitate additional growth; strategic infrastructure improvements are likely to lead to an increase in the number of homes needed locally; and, an authority has agreed to accommodate unmet housing needs from a neighbouring area. The first two circumstances are relevant to Greater Cambridge. Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. There is an urgent need to improve the affordability of housing and to boost affordable housing delivery in Greater Cambridge. Therefore, the emerging GCLP should use the standard method to calculate the minimum local housing need, and then make appropriate adjustments taking into account the growth strategies and strategic infrastructure improvements identified for Greater Cambridge, and a further adjustment to ensure affordable housing needs are met.

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Form ID: 45385
Respondent: Sharp Family
Agent: Carter Jonas

Yes, strongly agree

Yes. As set out in the response to Question 31, upward adjustments to the minimum figure derived from the standard method are required to take into account growth strategies, strategic infrastructure improvements and housing affordability in Greater Cambridgeshire. The National Infrastructure Commission, the Cambridge and Peterborough Combined Authority and the Greater Cambridge Greater Peterborough Enterprise Partnership acknowledge and support the economic growth potential of the Greater Cambridge area, and consider that there is a need to substantially increase housing delivery in order to support that economic growth and address the significant housing affordability issues that exist.

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Form ID: 45386
Respondent: Sharp Family
Agent: Carter Jonas

Paragraph 61 of NPPF expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. It is noted that the existing and planned new settlements in South Cambridgeshire and some of the strategic sites are not delivering policy compliant levels of affordable housing. As such, it is considered that emerging GCLP should seek to allocate sites which are capable of delivering policy compliant levels of affordable housing. The promoted development at land at Park Lane in Dry Drayton includes housing, affordable housing and self-build plots. It has been determined at appeal that there is a significant shortfall in the delivery of self-build housing in South Cambridgeshire (see Appeal Ref. APP/W0530/W/19/3230103).

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Form ID: 45388
Respondent: Sharp Family
Agent: Carter Jonas

Paragraph 103 of the NPPF seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised. Therefore, the site selection process for potential allocations in emerging CGLP will be an important part of increasing travel by sustainable modes of transport. The promoted development at land at Park Lane in Dry Drayton is accessible to the services and facilities in the village by walking, cycling and public transport, and the site would be well-related to the walking and cycling improvements on Madingley Road proposed by the Greater Cambridge Partnership.

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Form ID: 45389
Respondent: Sharp Family
Agent: Carter Jonas

Yes

Yes. Paragraph 136 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist, and those exceptional circumstances should be based on evidence and justified. Therefore, it is appropriate to consider whether to review Green Belt boundaries through the emerging GCLP. It is considered that exceptional circumstances exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge and the need to support economic growth. Paragraph 137 requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not straightforward and may be inappropriate because of heritage assets and the difficulty of finding alternative sites for existing uses. It is considered that the land at Park Lane in Dry Drayton makes a limited contribution to the purposes for including land within the Green Belt. The promoted development at the site would have no adverse impact on the compactness or setting of Cambridge and it would not lead to the merging of villages. Therefore, the site should be released from the Green Belt to meet needs for housing, affordable housing and self-build plots. The promoted development would provide affordable housing to meet local needs of the village – see South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2018).

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Form ID: 45394
Respondent: Sharp Family
Agent: Carter Jonas

Highly flexible

It is noted that the existing defined settlement boundaries for most villages in South Cambridgeshire have remained largely unchanged since the Local Plan 2004; although sites were allocated within and on the edge of some villages in the Site Specific Allocations DPD in 2010 and for the adopted South Cambridgeshire Local Plan 2018. It is very likely that most of the development opportunities within existing village boundaries would have been taken up by now. It is also likely that heritage assets within some villages, such as conservation areas and listed buildings, will constrain development opportunities. It is not clear whether the Councils have undertaken an assessment of the capacity of villages to accommodate additional development; it is likely that such an assessment would demonstrate that the capacity is limited. On the basis of the above, it is considered that the current site size threshold limits in the adopted South Cambridgeshire Local Plan 2018 are largely irrelevant and ineffective e.g. there are few outstanding development opportunities for up to 8 dwellings (or 15 dwellings on previously developed sites) within existing framework boundaries in Group Villages, and Dry Drayton is an example where there are few opportunities within the boundary. In any event, there are numerous examples between 2014 and 2019 when planning applications were approved and appeals were allowed on sites within and on the edge of settlements that were contrary to the existing site size threshold limits. Therefore, it is considered that the emerging GCLP should seek to allocate suitable sites on the edge of existing sustainable villages, in conjunction with a general policy that supports development within existing framework boundaries but without specifying any size limits. This suggested approach would ensure that sufficient land is allocated for development at villages to support services and facilities and ensure that sufficient affordable housing is provided to meet local needs in villages, including in Dry Drayton.

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