Proposed Development at West Cambourne – Application Reference S/2903/14/OL
South Cambridgeshire Hall Cambourne Business Park Cambourne Cambridge CB23 6EA t: 03450 450 500 f: 01954 713149 dx: DX 729500 Cambridge 15 minicom: 01480 376743 www.scambs.gov.uk
Steven Kosky St Andrews House St Andrews Road Cambridge CB4 1WB
Corporate Area: Planning and New Communities Our Ref: S/2903/14/OL Contact: Edward Durrant Your Ref: Direct dial: 01954 713266 Date: 13 March 2015 Direct email: [email protected]
Dear Steven,
RE: proposed development at West Cambourne – application reference S/2903/14/OL
Further to the submission of the outline application for the above development received on 22nd December 2014.
As you are aware the District Council’s draft local plan includes an allocation for Cambourne West (Policy SS/8) but this does not include the entire site edged red in your client’s planning application.
It is also the case that the Council is at present unable to demonstrate a five-year housing land supply. Under these circumstances, the Council must determine applications for housing against the National Planning Policy Framework (NPPF) paragraph 14, which puts at its heart a presumption in favour of sustainable development. Paragraph 14 states that sustainable development “should be seen as a golden thread running through both plan-making and decision-taking”. For decision taking it states that the test where policies are out of date, is that permission should be granted unless “any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole”.
The question for the Council is therefore whether the proposal comprises sustainable development under the terms of NPPF paragraph 14 and whether there would be significant harm were the application to be approved.
Having considered the case made in the planning application documentation, officers consider that whilst the proposed allocation in the Submission Local Plan remains sound, the arguments made by the applicant for development of the wider site have some merit. Especially with regards to place making and the comprehensive delivery of services and facilities that may not come forward if the additional land were developed as part of a potential, future allocation.
Cont/… 1
It is recognised that a lot of work has gone into the proposed masterplan and that designing it around the landscape constraints reflects the approach originally taken at Cambourne. However, there remain a number of key matters that would need to be addressed to ensure a sustainable development. The officer view is that if these matters can be satisfactorily addressed, it is anticipated that a recommendation of approval is likely to be appropriate.
This view takes particular account of the measures proposed in the Transport Strategy for Cambridge and South Cambridgeshire, which seeks to make significant improvements to sustainable modes of transport on the A428 corridor as part of supporting the development strategy for the Greater Cambridge area. The Submission Local Plan, currently at examination, identifies the strategic transport infrastructure required to deliver Cambourne West. This includes segregated bus priority measures at Madingley Hill and new park and ride on the A428 corridor as key parts of the transport strategy to improve public transport links between Cambourne and Cambridge. The major transport improvements on the A428 corridor are requirements of the Submission Local Plan Policy SS/8. These measures will help make a real difference to the sustainability of Cambourne, which due primarily to its historic location on the old A45 corridor (now A428), has so far developed as a heavily car dependent community.
Cambourne West, whether the draft allocation or the application site, offers the opportunity to reduce car dominance by making appropriate contributions to the delivery of major transport enhancements, along with the proposed development of a new settlement at Bourn Airfield. The City Deal Board has prioritised improvements to the A428 corridor, and work is progressing towards development of these schemes.
The proposal also has potential through the provision of greater facilities and opportunities for work to reduce trips out of Cambourne. However, the masterplan, and the documents that support it, unfortunately do not demonstrate an approach that would achieve this. Based on this it is unclear how your client’s aim of Cambourne West becoming a “sustainable neighbourhood” that enhances “the whole settlement in terms of Environmental, Social and Economic sustainability” would be met.
This letter includes the initial officer assessment of your client’s proposals, which are contained in appendix 1. Appendix 2 includes all of the statutory consultee responses that have not been included within the main body of the response due to their level of detail. Deficiencies have been identified in the level of information contained within the Environmental Statement (ES). Therefore this letter constitutes a formal Regulation 22 request under the Town and Country Planning (Environmental Impact Assessment) Regulations 2011. You should note that a number of representations were made by members of the public from Cambourne and the surrounding villages. These responses will be forwarded to you separately.
In order to enable officers to support the principle of the wider site being developed, we are keen to work with you to ensure that the necessary amendments and further information that is requested enables officers to be in a position to recommend the application for approval. A number of the comments made have a direct impact upon the spatial masterplan and in order to progress discussions with you and your client on how to take the proposals forward a series of themed meetings are suggested. One of these should clearly focus on changes to the spatial masterplan in order to address the issues raised in this letter.
It is hoped that the masterplan changes can be carried out in parallel with the work needed on amending the more technical documents to enable the application to be taken before the Planning Committee in the summer. I have included a draft timeline for the programme of work that is needed to reach a Planning Committee for you to consider and comment upon (appendix 3). Cont/… 2
Several meetings have already been put in the diary to discuss archaeology and transport. It is suggested that we also have a more general meeting to discuss the contents of this letter in the next fortnight and to agree a programme of work for the next few months. In the meantime if you require any further clarification on any of the points made in this letter please do not hesitate to contact me.
Yours sincerely
Edward Durrant Principal Planning Officer – Planning and New Communities
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Draft Timeline – Amendment to the Cambourne West planning application – S/2903/14/OL
1. Applicant to consider officer response letter dated 1 week w/c 16th on 13th March. March 2. Initial meeting to discuss response and agree 2 weeks 27th March programming and the schedule for themed meetings to address the issues identified. 3. Themed meetings covering masterplan, transport, 8 weeks 22nd May noise, archaeology, level of affordable housing and overall viability/S106 requirements, etc. 4. Amendment/additional information to be prepared 4 weeks 19th June by applicant and submitted. 5. SCDC to receive amendment and re-consult 4 weeks 17th July (minimum 3 week consultation period). 6. Review amended plans and comments received. – If 2 weeks 31st July no further information or amendments are required then officer recommendation can be made. 7. Determination 4 weeks August / Committee report drafted and checked September Conditions drafted/shared with developer team and reviewed Draft HoT finalised Application taken before Planning Committee 8. Following resolution, finalise Section 106 Agreement At least 3 November / and conditions. months December (post Committee) 9. Issue decision notice. 1 week December
ED/March 2015
Appendix 1 – Officer Response to S/2903/14/OL
Landscaping and open space
It is accepted that the level of publically accessible open space presently at Cambourne is unlikely to be replicated on Cambourne West. Notwithstanding this it appears that the definition of informal open space has been misinterpreted when making the calculations for the development, especially in relation to the tree belts. It is worth noting the definition below of areas that do not contribute towards open space standards, which is taken from the Council’s Open Space in New developments DPD.
Land which by virtue of its location, accessibility, size, density of vegetation, topography, long term condition, sub-standard safety or for any other reason, is not, and cannot be reasonably made, suitable for sport, recreation or play by the public.
At the pre-application stage it was highlighted that the water bodies would not contribute towards informal open space calculations, and the same is true for the areas shown as marsh and wet meadow. Areas of woodland, the primary function of which is to act as shelter belts, buffer strips, screening plantations etc. (to avoid the development from being seen as part of a ribbon of development along the A428 and to protect the rural character of the A1198 in accordance with draft Policy SS/8), should also not be included within the open space calculations. These long, narrow strips of potentially densely planted woodland would not provide meaningful and useful ‘open’ spaces. They would also have limited opportunities for recreation and would not preserve or enhance rural character by reflecting the best examples of the local landscape character.
It is accepted that there may be some play areas or glades within these tree belts, but the entire figure of 21.65ha of woodlands given on page 72 of the Design and Access Statement (D&A) would not contribute towards the informal open space requirements of the development.
The figure of 62.76ha on page 70 of the D&A, which is the area of land without built development on, should not be described as the amount of public open space as this is misleading. It is worth noting that different figures are also given within the D&A for informal open space. On page 59 a figure of 33.68 is given whilst on page 72 a figure of 36.99ha is given. In order to clarify the exact level of open space that is proposed, and to ensure it meets the required standards, it is requested that a more detailed breakdown of all the landscape features proposed as public open space be provided. This should be accompanied by a map showing the different landscape areas and calculations of the area of each one.
In addition to the issues with the quantum of open space there are also concerns about the relationship of the areas of informal open space and the primary road network. We have a fundamental objection to the approach that the green spaces of Cambourne are better experienced as part of a movement corridor dominated by vehicular traffic. By adopting this approach the proposed built form is not in keeping with the established character of Cambourne, which has been developed as three villages around central green spaces. Moreover, the beauty of the existing green spaces of Cambourne is that they can be enjoyed without users potentially coming into conflict with vehicular traffic. The narrowness of the proposed open spaces and their proximity of the spine road mean they are unlikely to be high quality spaces as the road and its associated infrastructure would dominate them. Further discussions
1 are needed on how the green spaces and movement corridor should interact to ensure that we create quality spaces that people feel safe to use.
We are still unconvinced about the recreation of the historical form of ‘Swansley Wood’, especially as it has the potential to separate the area of housing it encloses from the rest of the proposed development (i.e. barrier to achieving a mixed and balanced community). Again, the open space provided within the boundary does not appear to be particularly useful for informal recreation.
Previously we have raised the issue of the distribution of the allotments and how they should be more easily accessible by people living in the higher density areas, which tend to be flats with no gardens. We welcome further discussions with you and Cambourne Parish Council about the best distribution and management of the allotments.
Cambourne Parish Council has raised the need for additional burial space and has identified a need for 3.36ha of land. Given the issues with noise from the A428 it has been suggested that a potential location could be within the green buffer facing the road. However, it is accepted that this may not be the calmest of environments for grieving relatives.
Ecology
The requirement for species specific mitigation on the application site is limited to farmland/ground nesting birds, and a watching brief for badgers (should a sett become active again).The area of grassland to the southeast of the proposed allotments has been identified as an ideal habitat for skylarks. Especially as the proposal to continue the existing tree belt to enclose it would result in the land having limited public accessibility. This area is considered necessary as habitat to mitigate the loss of the fields used by farmland birds. Areas of land managed specifically as part of an approved mitigation and/or compensation scheme would not contribute towards the open space calculation. As this area appears to be included in the open space calculations its omission from the final figure would have implications for the amount of public open space proposed across the site. The proposed bridleway through this area would need careful thought to ensure that habitat disturbance is kept low.
There is the presence of the invasive, non-native Japanese knotweed within the curtilage of Swansley Wood Farm. This plant will need to be removed if/when that parcel of land comes forward for development; at present a watching brief should be in place to ensure that it does not spread into the site.
To off-set harm resulting from the development, some habitat creation should be undertaken at an early stage to provide habitat continuity: early creation of the habitats will provide alternative feeding habitat and breeding sites for common toads, badgers, starlings, house sparrows and dunnocks. As the habitats mature it is likely that bats, yellowhammer and linnet will also benefit. But as the development becomes more populated by people (plus dogs and cats), it is likely the sensitive species such as brown hare, skylark and corn bunting, for example, will become scarcer unless secluded areas are retained.
During the construction phase, it is necessary for typical safeguards to be in place, e.g. pre-commencement ecological checks such as nesting bird checks, delivery of ecological tool box talks, pollution-prevention controls in the vicinity of waterbodies,
2 ecological watching briefs during potentially sensitive works, and instructions on when ecological advice must be sought and mechanisms for reporting.
Specific ecological checks which will need to be undertaken prior to commencement of work in any plot are: Checks to ensure that there are no new badger setts within 30m of the working area; Assessments, and where necessary emergence watches, for bats on any tree scheduled for felling; and Checks on any vegetation that is removed during the bird breeding season for the presence of nesting birds, including checks for ground nesting species.
Employment
In the Wessex Economics Cambourne Employment Sites Study Cambourne is identified as “very far from being a self-contained community”. A number of the representations have also highlighted the fact that Cambourne is seen as a dormitory settlement. The report identifies that at the time of the 2011 census there were approximately 3,250 jobs in Cambourne with 3,100 homes, “so broadly there was a balance between jobs and homes”. The same report estimates that when existing Cambourne and the proposed development are fully built out there would be 6,320 jobs for 6,600 homes, based on the proposed 5.66ha employment and existing employment sites being developed. This clearly demonstrates a shift in the balance of homes against jobs.
The employment land either side of Sheepfold Lane was not included in the Council’s proposed site allocation in the Submission Local Plan, as it was allocated for employment under the original outline consent for Cambourne (S/1371/92/O). Although the period within which reserved matters applications can be submitted under the original consent has now expired the masterplan designation is still considered material. Therefore the only ‘new’ employment proposed would be the 4.41ha in the north eastern corner of the site.
One of the Council’s planning objectives for the whole of the district is for development to be sustainable. Part of the rationale for extending Cambourne accepted by the Council and your clients is that an increase in the number of homes makes Cambourne more sustainable. This would be as a result of the provision of more facilities and services, which would then allow greater internalisation of residents’ movements. The 2011 census identified that 90% of residents work outside of Cambourne, at a time when there was a relative balance between homes and employment. The greater imbalance identified by Wessex Economics, once the proposed development is built out, has the potential for Cambourne to become more of a dormitory settlement than it is presently.
South Cambridgeshire Submission Local Plan Policy SS/8 requires 8.1ha of employment land to be delivered in lieu of any employment land lost at Cambourne Business Park. The Wessex report wrongly assumes that the Council’s approach to the Business Park is an acceptance that the employment land will not be developed. The draft policy reflects recognition of the fact that the existing employment offer of the Business Park is outdated and that with development to the west of Cambourne the Business Park would become a pivotal area within a larger Cambourne. At night and in the evenings the Business Park is a sterile environment with little or no activity. The proposals for some residential development on the Business Park would ensure that it becomes more of a vibrant area that encourages greater movement between Cambourne West and the rest of the settlement, especially if access to your client’s site can be secured via the Business Park road. The Submission Local Plan
3 also recognises the need for a greater mix of employment buildings, including smaller units.
The Wessex study does not give any consideration of how Cambourne’s position would change as a result of the proposed public transport improvements as part of City Deal. These changes clearly have the potential to transform Cambourne’s prospects for attracting employers, especially as employment sites within the city are being redeveloped for housing.
The report identifies that in order to encourage employment at Cambourne an “attractive environment” is needed together with a critical mass to encourage take up of “business with common areas of interest”. Based on the limited information of the proposed employment area it is unclear how both these statements would be fulfilled. Moreover, there is no consideration of whether the trend in hybrid employment space could be encouraged at Cambourne and what impact this would have on the creation of jobs. We would be keen to take an innovative approach to the delivery of business units that meet the needs of existing and future Cambourne residents rather than accepting that Cambourne will continue to have a low level of self-containment.
The view that Cambourne employment should increase in line with housing has a sustainability argument as clearly there is greater potential for trips to be internalised and sustainable transport used if more employment opportunities exist within the settlement. The argument that this is flawed thinking and that Cambourne should provide less employment land is accepting that it will become a dormitory settlement. Essentially without a choice of employment locally people will have to travel elsewhere to earn a living. There is also the need to create a balanced community with activity during the daytime when residential areas have less activity.
The report recognises that the best place in Cambourne for employment would be on the Business Park, as it is well served in terms of road access, is located close to Cambourne centre, and is part of an established employment zone. This would reinforce the Council’s view that the employment provision on Cambourne West should be located near to the Business Park in order to create a cluster that the report identifies as being desirable. Cambourne Parish Council’s comments about access to the employment land are also based on the poor connectivity and integration of the site within the masterplan. Based on the Wessex study it is unclear why the proposed employment land is located in the most remote part of the site, away from the existing employment cluster and Cambourne centre. Moreover, reference to Buckingway Business Park and Papworth Business Park are not comparable to Cambourne in terms of the scale of the villages they abut and the geographical locations on their peripheries.
Further discussions are needed on the level and mix of employment at Cambourne West and where it would best be located. These discussions will clearly have an impact upon the spatial masterplan. The interaction with the emerging proposals on the Business Park land, and the potential for an access through it to Cambourne West, should also be actively explored. The delivery of employment units either side of Sheepfold Lane would need to be carefully designed to ensure that they are of an appropriate scale in the street scene sitting between the taller units of the Business Park and BMW garage and the residential units proposed to the west of the tree belt.
Based on the fact that employment and retail has lagged behind the delivery of housing at Cambourne we would require a strategy for the delivery of employment and retail units. The present phasing shows the main employment area coming through late on it the development based partly on its location. This strengthens the
4 argument for greater integration of employment land within the masterplan and a strategy for its delivery.
Housing
The Pioneer Housing report was seen informally before the submission of the application. As you are aware any reduction in the draft policy requirement (H/9 – Affordable Housing) for a minimum of 40% affordable housing is based on viability alone. Therefore until a strong justification has been provided, based on viability, the policy requirement stands.
The report’s argument regarding welfare reform and that the affordable housing needs to be at the smaller end of the property market is not appropriate given that the Cambridge sub-region has the lowest rate of unemployment. Evidence from the Southern Fringe allocations is suggesting that over 60% of all affordable housing allocations are going to working households. The majority of applicants who are housed by the Local Authority who are in receipt of housing benefit tend to be of pensionable age. With the proposed affordable housing mix in the Pioneer report 72% of the affordable homes would be 1 and 2 bedroom homes, which would be mainly apartments. Based on this it is not clear how your client is proposing to deliver a mixed, sustainable community as required by the NPPF.
The draft Local Plan and the SHMA data clearly indicate the need for smaller dwellings regardless of tenure. South Cambridgeshire Submission Local Plan Policy H/8 (Housing Mix) requires that market housing within a development of 10 or more homes will consist of At least 30% 1 or 2 bedroom homes At least 30% 3 bedroom homes At least 30% 4 or more bedroom homes With a 10% flexibility allowance that can be added to any of the above categories taking account of local circumstances,
There is currently a lack of public subsidy from central government in delivering affordable housing, but many affordable housing providers are using there own resources to assist in the delivery of affordable homes across Cambridgeshire and feeding into current viability assessments e.g. Wing and Southern Fringe.
We would welcome further discussions with you and your client on the housing mix that is proposed, no details of which have been provided, and the delivery of affordable housing across the site.
Although the proposed density across the site is broadly acceptable we would like to discuss whether the density should be more varied, with the higher density located along the primary route. Based on the comments on the level of public open space and employment land that are proposed it is inevitable that there will need to be changes to the masterplan. These changes could potentially result in the areas of developable land reducing and it should be recognised that the overall number of homes may need to reduce.
Education
It is recognised that in order to meet the secondary school requirements for the proposed development another secondary school would be required. The County Council has made comments about the requirement for a site but before the masterplan can be agreed the proposed location of the second secondary school
5 may need further consideration. Previously we have expressed concerns about how the two school sites would form a physical barrier between Cambourne West and Lower Cambourne and now the County Council is also questioning how the two sites would work together as part of the proposed layout.
The implications of having so many schools (two primary and two secondary) in close proximity to each other and the impact this would upon the surrounding road network at the start and end of the school day has been questioned. Further discussions are needed to understand how the location of the school buildings, local centre and sports facilities can form a centrally accessible, vibrant hub. We would expect these to contribute towards achieving a high quality public realm and encourage activities throughout different times of the day.
Once the masterplan has been agreed the parameter plans will need amending to enable the school sites to accommodate a built form of up to 15 metres. This will give the education provider greater flexibility in designing the schools. Primary school site 1 also needs to increase to 2.3 ha. More detailed comments are contained in the attached County Council response in appendix 2, the majority of which will need to be secured through the Section 106 legal agreement (S106).
There is limited information on the proposals for the provision for youth and pre- school across the development. Though it is accepted that these can be secured through the S106.
Although there is no requirement for a new library facility on Cambourne West there need to be proposals for an enhancement of the existing facility at Sackville House to take into account the increased population. Again, this is a matter that can be addressed through the S106.
Connectivity, Access Arrangements and Transport Infrastructure
In my pre-application letter of 8th October 2014 I raised concerns that the proposed locations of the second secondary school and allotments would, when combined with the existing school sites, create an extensive, securely fenced area. This proposed layout would essentially separate Cambourne West from Lower Cambourne especially as the green spaces within the school sites and allotments would not be publically accessible.
There are very limited footpath or cycle way connections to link the proposed development with the rest of Cambourne. Similarly there are limited details of proposed pedestrian and cycle links to the surrounding villages and how a high quality cycle link would be created to west Cambridge, in accordance with the requirements of draft Policy SS/8.
Improved cycling infrastructure along the old A428 would help to calm what is presently a hostile environment for cyclists, primarily due to vehicle speeds along the road. However, it is not felt that the proposed white lines would achieve this. We welcome the opportunity to discuss how Cambourne West can improve cycle and pedestrian links to the surrounding communities with your client and relevant stakeholders.
As early haul roads are proposed off the A1198 it is questioned whether a temporary cycle pedestrian route to Caxton Gibbet could also be put in alongside them, with the necessary segregation in place. This would allow access to the units there before the permanent routes are in place.
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The aim of draft Policy SS/8 was to bring both McA and Development Securities together to develop a comprehensive masterplan for the Cambourne West site. A crucial part of this masterplan was the link road through the Business Park. On-going discussions with Development Securities appear to indicate that some form of access through the Business Park to Cambourne West is achievable. The masterplan should therefore take this into account. One of the areas that would need further attention is the location of the local centre, and its relationship with the Business Park. If an access through the Business Park can be achieved then it may negate the need for the significant works proposed to allow greater traffic flows through the Sheepfold Lane junction. As raised previously, as a gateway to your client’s proposed development, Sheepfold Lane is far from ideal and Members have recently expressed concerns about the scale of new highway accesses on developments across the district.
Notwithstanding the above comments Sheepfold Lane would still serve a function as, hopefully, one of the gateways into Cambourne West from the east. If it were to be accepted that it was the primary access then there are serious concerns about the proposed reconfiguration of the Cambourne Road roundabout and the impact it would have on pedestrians and cyclists. The same applies to the Caxton bypass roundabout. Cambourne West needs to actively promote walking and cycling and the transport infrastructure needs to ensure safe routes for pedestrians and cyclists. At present we feel that the masterplan fails to achieve this.
It is disappointing that the proposed bus link from Upper Cambourne onto the Broadway has still not come forward. In promoting public transport for Cambourne West and achieving a modal shift away from the private car this bus link is key and a commitment to its delivery is needed. A number of inaccuracies have been identified in the public transport data that has been provided in the ES. There also needs to be consideration of whether a bus service to St Neots could be subsidised if it can be shown to be a commercially viable route in the long term.
A number of representations have identified that the perimeter route is shown as a bridleway on some drawings and a footpath on others. To clarify we would expect to see the entire route as a bridleway in keeping with the existing perimeter bridleway. It is also requested that the footpath through to Caxton, which also connects with the footpath up to the secondary school, be upgraded to a bridleway to allow greater connectivity.
Transport Assessment (TA)
The County Council has put in a holding objection until the proposal can demonstrate the adequate mitigation of its impacts. A number of inaccuracies and out of date information has been identified in the TA. For example the Baseline Traffic Survey and further trip data is required. As such the County Council is not convinced that the full impact of the development has been considered. Further information is also needed on the interaction of the proposed development with the A428 corridor City Deal schemes, and phasing of development in relation to these improvements. Full details of the County Council response are in appendix 2. Agreeing changes to the TA is critical in the timeline for determining the application. The impact of increase traffic through the surrounding villages has been raised by the majority of the parish councils who responded, especially those on the B1046. Early discussions with the County Council indicate that in the short term small scale mitigation schemes may be needed in the surrounding villages until such time as the larger scale improvement to the A14 and on the A428 corridor are completed.
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The Highways Agency has put in a holding objection and we hope to have their comments shortly. Once we have them I shall forward them on to you.
Travel planning
Detailed comments on travel planning are contained within the County Council’s response. It is requested that stretching targets be proposed based on achieving a modal shift across the whole of Cambourne to mitigate the impact of Cambourne West rather than just focusing on the development itself.
The experience of the travel planning for the additional 950 homes at Upper Cambourne has not been an entirely positive one and the Travel Plan Coordinator only appears to have been active following concerns that the agreed Travel Plan was not being implemented. We would therefore expect to see a more robust approach to travel planning for Cambourne West with work starting before any residents move onto site.
Sustainability
The vision of Cambourne West enhancing the environmental sustainability of the whole settlement is not reflected in the proposals. The Council’s policies require your client to exceed minimum standards. It is important to recognise that the energy efficiency policies are a requirement that we would expect to be complied with, and where possible exceeded. Therefore comments that your client "will strive to meet the requirements of NE/2” are not acceptable. Moreover, the requirement is not subject to viability.
Although the innovative proposals to meeting the sustainable energy requirements through the ‘Renewables Fund Contribution’ for the 950 was a success it is questioned whether the same approach is acceptable for Cambourne West. The 950 proposals worked because it resulted in installing Photo Voltaic (PV) panels on most of the public buildings in Cambourne and there is only capacity on these buildings for further panels. Moreover, the new public building on Cambourne West will be required the meet the 10% renewable energy requirement themselves.
The proposals within the Sustainability Statement for money to go to the County Council to be spent with elsewhere in the County are unacceptable and would not meet the policy requirement for the energy to be generated on site.
The Sustainability Statement refers to the Code for Sustainable Homes (CfSH) and the Housing Standards review and although this may have been accurate at the time of writing (August 2014), it is now out of date due to changes to Part L of Building Regulations. It is obviously important that your client ensures any standards set by Building Regulations are met, but policies NE/1 and NE/3 are crucial drivers for the energy standards of the development. The statement provided suggests that the development will achieve a level 3 under the CfSH’s, which is poor compared to a number of other sites across the district. Level 3 means that dwellings must be constructed to achieve a 25% CO2 reduction on Part L of 2006 Building Regulations.
The Housing Standards Review referred to has meant that as of April 2014, the minimum requirements of Building Regulations are a 31% CO2 improvement on 2006 Building Regulations. This would mean that the proposals put forward in this sustainability statement fall short of current Building Regulations by 6%.
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Although the Code for Sustainable Homes is to be ‘wound down’, it is still a very good tool for assessing the sustainability of a development and we would encourage your client to consider achieving a minimum of CfSH’s level 4, which equates to a 44% CO2 reduction over Part L 2006. It is worth noting that Central Government are due to increase the minimum requirements of Building Regulations Part L again in 2016, although there is still some uncertainty as to the extent of the increase.
The Sustainability Statement refers to a number of energy efficiency features that will require detailed consideration during the next stages of the development, including the use of dynamic building modelling. We would therefore expect a development of this size to carefully consider all aspects of the built form in a bid to reduce energy demand. The Council’s District Design Guide SPD is very clear as to the environmental sustainability criteria that it expects applicants for planning permission to take account of in their proposals relating to sustainability. The document stresses the need for developers to consider layout and orientation, building form and structure, technology availability and suitability and occupancy behaviour.
Your client recognises the need for 10% of the predicted energy requirements to be met by onsite renewables and the calculations provided are accurate in recognising the kWh’s of energy that need to be provided onsite. The initial assessment of PV as an option for meeting this requirement is as we would expect but it does only offer 8% of energy produced on site, therefore this would need to be increased or supported by another form of renewable technology (possibly solar thermal) in a bid to ensure a minimum of 10%.
A development of this size should go above the 10% requirement and in some areas your client will be required by the Council’s existing and policies to achieve more. The statement refers to some initial desk top assessments of a good range of renewable technology options and obviously these will need to be considered more carefully to ensure the minimum 10% is met. We would condition the fact that the development must meet a minimum of 10% of its predicted energy requirements (kWh) via onsite renewable energy technology.
Sports provision
Sport England does not advocate the provision of grass athletics tracks for community use as such facilities are often provided on school sites for curriculum use. Community facilities for athletics are normally provided via an all-weather track, which is suitable for club use and contains facilities for field events as well as suitable ancillary facilities. Although it is recognised that this is a facility specifically requested by Cambourne Parish Council it is unclear whether this is the most suitable facility for the development and we would welcome further discussion on this.
The main playing pitches are proposed on the land to the north of the proposed athletics track and it is assumed that they will not be floodlit as no consideration of this has been included in the ES. Based on the irregular shape of this site it does not appear to be ideal for the siting of pitches. Therefore it is necessary to see a more detailed layout plan for this land to ascertain the number, size and type of pitches to be provided and whether they can be accommodated on the site. The quality of this environment, adjacent to the A428, is also questioned by Environmental Health Officers. If bunding is required to reduce noise from the road then this will also impact upon the layout of sports pitches.
There are concerns that the sports facilities are not well distributed across the site.
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The second area for formal sport, adjacent to western primary school, appears to be much smaller and suitable only for small-sided football or rugby. If this is the case it might not be essential to provide changing facilities as mini/junior soccer players do not normally use changing facilities. Again, it would be easier to comment further on this element if more detailed plans were available for this site.
There is no detail of provision for indoor sports across the site. Although these could be secured through the S106 further information is needed on the proposed location and quantum of space to be provided. As you are aware Cambourne Parish Council has aspirations for a swimming pool. This is something that will need further discussion with the Parish Council.
Community facilities
Both the NHS and Cambourne Parish Council have suggested that a household multiplier of 2.74 be used rather than 2.7. This would be prudent based on the history of the delivery of education across Cambourne. This will also have implications for the levels of sports, open space etc.
Although the quantum of space for community uses is acceptable the delivery of the facilities would not appear to come forward at the same time as the early housing parcels. Given the isolated nature of both the early phases of homes, which would be remote from the facilities of Cambourne for some time, getting interim community facilities in early will be key in building the new community. The early delivery of pedestrian and cycle routes, ideally through the Business Park, would also be key to create cohesion between the new and existing communities of Cambourne and Caxton.
Community development workers will be required from an early stage and money will need to be secured through the S106 to fund these posts.
Health
The NHS has confirmed that the assertions made in the application about expansion of the Health facility at Sackville House being the NHS commissioners preferred option for providing additional capacity is correct. However, it has also identified that the capacity data in the Health Impact Assessment (HIA) is incorrect and has ignored the restrictions arising from practice boundaries and the constraints of the existing infrastructure and that the proposed development will have major, not moderate impact on Health services.
The issue of health provision across Cambourne has been raised by a number of public responses and Cambourne Parish Council. It is recognised that this issues relate primarily to central government funding and would like to work with your client, Cambourne Parish Council and the NHS to ensure that the situation at Cambourne is given due consideration. Full details of the NHS’s response are contained in appendix 2.
Further, more detailed, comments on the HIA are contained in appendix 2
Archaeology
The Design and Access Statement identifies that trial trenching will inform the requirements for open area excavations and could potentially result in the preservation in-situ of artefacts. The retention of artefacts in-situ clearly has the
10 ability to impact upon the location of open space throughout the development and impact upon the masterplan.
Archaeological investigations undertaken during the development of Cambourne to the east demonstrated that this landscape was extensively and intensively settled and managed from the Middle Iron Age to the early Saxon period (Wessex Archaeology Report Number 23). Investigations in advance of improvements to the A428 adjacent to Cambourne also contributed to this understanding of the late prehistoric and Roman landscape (Albion Archaeology, EAA 123).
Surveys undertaken in support of the application (aerial photographic assessment and geophysical survey) indicate areas of settlement and related activity. Some of these appear to be very extensive in nature and likely continuous (AP5 and AP6). Others, such as the area of settlement identified as AP6 and the enclosures at AP4 give the impression of being contained. However, the fieldwork undertaken in advance of construction of the new school site demonstrated that features relating to these areas of settlement extend beyond the areas of visible cropmarks (HER ECB3735). The proximity to the major Roman Road Ermine Street (HER 15034) increases the importance of the area and the potential for highly significant archaeology.
Swansley Wood Farm is a moated manor of medieval origin. Although excluded from the application area, this site is unlikely to have existed in isolation and additional evidence for medieval settlement and land use can be anticipated in the surrounding area.
The site of RAF Caxton Gibbet is located within the northern part of the site and evidence for this is recorded in the aerial photographic assessment. The site has heritage value in terms of Cambridgeshire’s role in the Second World War and should also be considered as a heritage asset. It is worth noting that there is a relatively in-tact Oakington style pillbox at the centre of the site, which should have been identified as a non-designated heritage asset. Given the limited above ground heritage assets across the site we would request that your client commit to the integration of the pillbox into the designs for Cambourne West. We would be keen to discuss with you ways in which it could be preserved and potential future uses.
County Archaeologists believe that there is high potential for significant archaeology of Iron Age, Roman, Early Saxon, Medieval and modern date to survive in the proposed development area. Surface artefacts also suggest a Bronze Age presence in the landscape (HER 11874). The National Planning Policy Framework paragraph 128 states: In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets to be affected. In also states that where a site on which development is proposed includes or has the potential to include heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk based assessment and, where necessary, a field evaluation.
The Cambridgeshire Historic Environment Record and your client’s own assessment conclusively demonstrate the presence of assets with archaeological interest. Our understanding of the landscape strongly indicates that these will be more extensive than can be defined from aerial photographic and geophysical surveys. Furthermore, there is potential for additional assets to be present which have not been responsive to the surveys undertaken to date. It is not possible to adequately assess the extent
11 and significance of these heritage assets on the basis of information currently available.
The Environmental Statement (ES) suggests that it has not been possible to undertake fieldwalking or trial trenching surveys due to the agricultural crop cycle (13.112). However, County Archaeologists have been advising this approach for over a year, and issued a design brief for this work in March 2014.
The ES proposes trial trench evaluation as a mitigation strategy but goes on to suggest that mitigation will be developed subsequent to this (13.113). The ES also suggests generic principles of preservation in situ or by record. Such evaluation would not be an appropriate mitigation response as it is intended to define the character, extent and significance of heritage assets likely to be affected by development and provide information to determine appropriate mitigation strategies. This approach is contrary to 2011 Environmental Impact Assessment Regulations. Schedule 4 lists for inclusion: A description of the likely significant effects of the development on the environmental, which should cover the direct effects and any indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative effects of the development (Part 4). In the absence of field testing, it is not possible to determine the significance of the heritage assets known to be present, or of the location, extent and significance of assets which have not been responsive to the limited surveys undertaken to date.
In order to successfully implement preservation in situ, it must be targeted on defined archaeological assets. It would not be appropriate to pick areas of convenience for preservation in situ or to attempt preservation of parts of heritage assets while destroying the remainder. To do so would result in the fragmentation of assets with a resultant loss of understanding and significance. It should be noted that the work undertaken to date indicates that some archaeological assets cover a considerable area (e.g. AP5 and AP6). In the context of the development proposal it is difficult to see how the preservation of these assets in situ could be achieved. Similarly, where preservation by record is to be preferred, we would expect programmes of excavation to address identifiable archaeological assets in a single programme of work. To split the investigation of assets across phases of development would also result in their fragmentation and consequent loss of significance and understanding.
The advice from the County Council is that: the application does not adequately define the character, extent and significance of archaeological assets likely to be effected by development; the application does not make appropriate provision for the management and mitigation of the archaeological resources within the site; in bringing forward development proposals without an adequate understanding of the archaeological context of the landscape, the applicant is does not consider the potential positive contribution that the historic environment can make to place making and the character of the new settlement.
Unless the above points can be address officer would not be in a position to recommend the approval of the application. It is therefore necessary to set up a meeting with the County Archaeologists so that the extent of trial trenching can be agreed. The work can then be carried out in parallel to the work on the masterplan so any requirements for the preservation of artefacts in-situ are reflected in the amendment masterplan and an updated ES.
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Noise and Environmental Health
Detailed responses from Environmental Health Officers are contained in appendix 2. However, it is worth noting that the view of specialist officers is that the application documents are lacking sufficient detail/assessment on a number of issues. In particular in relation to traffic noise impacts/effects from the A428 and to a lesser extent the A1198. The significance of impact/effects associated with traffic noise have not been adequately assessed and therefore the proposed traffic noise mitigation measures are not acceptable, or the mitigation proposed has not been fully justified.
The traffic noise from the A428 in particular has the potential to have a significant adverse impact on the health and quality of life of future residents and the overall quality of the development site generally including the public realm, informal and formal open space and recreational areas. In addition it has not been demonstrated that such significant adverse impacts/effects or just adverse impact as a result of traffic noise have been minimised. As proposed large areas of the residential parcels to the north of the site, the sports pitches and some of the western housing parcels would be subject to noise levels which we would consider as having a Significant Observed Adverse Effect Level.
In our specialist officer’s view this would be contrary to NPPF paragraphs 109, 120, 123, Policy NE/15 of the adopted Local Development Framework 2007 and one of the core planning principles of the NPPF which is to “always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings”.
This outstanding issue needs to be resolved prior to determination and before we can make reasoned and informed decision further assessment, information and or clarifications are required on the noise issues. There could also be significant implications for the spatial masterplan if bunding is required.
These issues need to be addressed before consideration can be given to the formulation of detailed planning conditions and S106 obligation / requirement requests, which may be required to secure the mitigation of any potential adverse impacts and secure effective service provision.
To address our traffic noise concerns, it is the specialist officer’s view that as a minimum consideration should be given to the provision of a substantive environmental noise barrier in the form of an earth bund (similar to those that exist at comparable residential locations in Cambourne along the A428) or acoustic fence / barrier or a combination running continuously along the entire development site boundary with the A428 and possibly along the A1190. The final height and length of such an environmental noise barrier or barrier could only be finalised by detailed noise modelling but to be effective it would have to be of such a height to block the direct line of sight to proposed residential property and habitable rooms. However in considering such a barrier constraints such as existing access roads / tracks and the presence of surface water attenuation ponds / drainage features along and close to the A428 would need consideration. In addition care should be taken when considering such mitigation to ensure the envisaged measures do not make for an unsatisfactory development in other planning respects in terms of urban design or visual impact requirements or loss of open space provision etc.
As this is potentially a fundamental issue the principle of providing such an environmental noise barrier should be explored prior to determination of this
13 application so that the mitigation that could be provided is determined with some degree of certainty or otherwise discounted.
Further discussions are therefore needed to ensure that sufficient noise buffers/mitigation measures are included alongside the A428 and A1198 boundaries. The approach should be based around landscape principles to ensure that whatever the approach that is agreed it is suitably screened by landscaping to limit the visual impact. Given the concerns about the location of the employment land an alternative could be to use non-residential buildings as a buffer from the noise of the A428.
Waste
Until the requirements set out in the RECAP waste Management Design Guide SPD are met the County Council maintains a holding objection. These requirements should be able to be met through the S106 discussions in order to remove this objection. Further comments relating to the detailed design stage are provided in the appendix 2.
Drainage
As you are aware the Environment Agency (EA) has raised an objection based on the details contained within the flood risk assessment. Their comments are contained within appendix 2. It appears that addressing the EA’s objection is achievable and I understand your consultants are already scoping out the additional work that is required.
Anglian Water has not objected to the application but has suggested a number of conditions, which are detailed in appendix 2.
Accumulative impact
The accumulative impact section of the ES has identified a number of developments in Huntingdonshire. There are a couple of significant develop that have not been included in table 2.2. These are:
1300388OUT - Loves Farm Eastern Expansion outline application for up to 1,020 homes and other uses.
1101368OUT - Land North Of Cambridge Road St Neots. Hybrid application for outline planning permission (with all matters reserved for subsequent approval) for 110 houses and full planning permission for a foodstore and 6 retail units.
The ES therefore needs to be amended to include these developments.
Self Build
We have already had initial discussions with you and your client about the provision of self built at Cambourne. As the plans for Cambourne West progress we welcome the opportunity to have further discussions to see how self-build will be incorporated into the proposals.
Submitting amendments
Following this letter we expect to set up themed meetings over the next few months in an attempt to address the issues identified. Once you are in a position to amend
14 the application and provided the additional information that is requested we would expect this to come in as a single amendment. The piecemeal submission of amendments and information would not be appropriate as it would create significant issues with document management and consultation. In terms of future consultation we would expect to give at least 21 days for consultees and members of the public to comment on the amended plans. Subject to the responses that are received, and the length of time taken to agree and produce them, we would anticipate potentially taking the application before planning committee in the late summer.
Meetings have already been set up to discuss archaeology and the TA. In addition to these it is critical that we address the issue of noise from the A428 and how this will be addressed due to the potential impacts any bunding would have upon the spatial masterplan. It may also be worth setting up a design day where all of the specialist officers can attend to map the constraints that have been identified. This would then better influence the amendments needed to the masterplan.
Extension of time
The application is presently due to be determined by 23rd March. Based on all the changes that have been identified as needed for officers to support the proposals it is requested that an extension of time be granted. The exact date for which the extension is agreed ca be subject to discussions once you respond to the draft timeline in appendix 3.
Boundary review
All through this letter reference has been made to Cambourne Parish Council it is recognised that the majority of the site falls within Caxton parish. The chair of Cambourne Parish Council has discussed a potential boundary review with Caxton Parish Council. Once we are in a position to support the proposed development we are keen to progress with the governance arrangement to ensure they are in place before residents move onto site.
Draft Head of Terms (HoT) and Viability
A number of the issues raised will need to be addressed through the S106 and some consultees have already suggested contributions that will be required. Work on the draft HoT will need to be carried out in parallel with the masterplan changes to ensure that it is sufficiently advanced to be taken to planning committee with the application. One of the areas not addressed in the application is public art. A strategy for the delivery of public art across the site will need to be secured through the S106.
It is assumed that there will be a viability argument made based on the proposed level of affordable housing suggested in the Pioneer report. This has the potential to impact upon the timeline for agreeing the draft HoT and level of S106 contributions. We would appreciate early discussions with you and your client on this.
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List of statutory Consultee responses contained in Appendix 2
Anglian Water Barton Parish Council Bourn Parish Council Caldecote Parish Council Cambourne Parish Council Cambourne Church Cambridge Cycling Campaign Cambridgeshire Fire and Rescue Cambridgeshire County Council Caxton Parish Council Croydon Parish Council CPRE Eltisley Parish Council Elsworth Parish Council Environment Agency Greg Kearney (Noise Specialist – Joint SCDC response including air quality and contaminated land) Hardwick Parish Council Hatley Parish Council Highways Agency Iain Green (Public Health Specialist - SCDC) Kylie Laws (Waste Management Specialist – SCDC) Local Access Forum National Planning Casework Unit Natural England NHS Property Services Police Architectural Liaison Officer Sport England Sustrans Toft Parish Council
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Planning Applications – Suggested Informative
Statements and Conditions Report
AW Reference: 00005297
Local Planning Authority: South Cambridgeshire District Council
Site: Land to the West of Cambourne
Proposal: Mixed use development including up to 2350 residential units
Planning Application: S/2903/14/OL
Prepared by Sue Bull, Planning Liaison Manager
Date 20 February 2015
If you would like to discuss any of the points in this document please contact me on 01733 414690 or email [email protected]
ASSETS
Section 1 – Assets Affected
Our records show that there are no assets owned by Anglian Water or those subject to an adoption agreement within the development site boundary.
WASTEWATER SERVICES
Section 2 – Wastewater Treatment
There are a number of Water Recycling Centres in the vicinity of the development site that have available capacity to serve the development one of which is Papworth Everard and it is this WRC that at this stage is being considered to receive the flows from this proposed development.
Section 3 – Foul Sewerage Network
A development of this scale will require upgrades to the foul network as without them it would pose an unacceptable risk of flooding downstream. A drainage solution is needed to be prepared in consultation with Anglian Water to determine mitigation measures against flooding. Anglian Water has been approached via our pre planning service by the applicant/applicants agent and a high level potential solution has been identified. However, this may change at detailed design stage. If the Planning Authority is mindful to grant permission Anglian Water would strongly recommend that a drainage condition is applied:
No development shall commence until a foul water solution has been submitted to and approved in writing by the Local Planning Authority. No dwellings shall be occupied until the works have been carried out in accordance with the foul water solution so approved unless otherwise approved in writing by the Local Planning Authority.
REASON To prevent environmental and amenity problems arising from flooding.
Section 4 – Surface Water Disposal
The surface water strategy/flood risk assessment submitted with the planning application indicates a sustainable drainage system that does not involve connection to main sewer.
There has been high level discussion with the applicant on the potential adoption of sustainable drainage system infrastructure although at this early stage there is no agreement in place. To ensure that a suitable and effective surface water strategy is agreed and implemented we strongly recommend, if the Planning Authority is mindful to grant permission that a surface water drainage condition is applied:
No drainage works shall commence until a surface water management strategy has been submitted to and approved in writing by the Local Planning Authority. No hard-standing areas to be constructed until the works have been carried out in accordance with the surface water strategy so approved unless otherwise agreed in writing by the Local Planning Authority.
REASON To prevent environmental and amenity problems arising from flooding.
04/03/2015
BARTON PARISH COUNCIL
Margaret Penston Chair
Patrick De Backer Parish Clerk [email protected]
www.barton-cambs.org.uk
Ed, Our comments from yesterday evening. Patrick
Barton Parish Council met yesterday evening and wishes to make the following comments about development at Cambourne West.
The Council has no particular view on the housing development itself.
However, the Council adamantly urges all relevant authorities to create an eastbound link between the A428 and the M11 prior to this development. A considerable number of drivers already uses this route to get to work. It also makes sense to have Park and Ride facilities in the Cambourne area with a dedicated bus lane into the City. Without the A428-M11 link current local roads will come to a halt and rural villages will be used as a rat run, with a resulting danger to schoolchildren, pedestrians and motorists.
MATTER 7A/16748 Statement on behalf of Bourn Parish Council (Representations 59165 and 59159) in response to the Inspector’s Matters and Issues for Joint Hearing Sessions, Block 2 in February 2015
This statement is submitted by Bourn Parish Council on behalf of the Coalition of Parish Councils, which was formed to oppose unsustainable major housing developments in the A428 corridor1. It responds to issues under Matter 7A (Strategic Transport Issues).
In order to address the Inspector’s Strategic Transport Issues, we undertook a traffic survey in the A428/A603 corridor. The results of this survey are presented at Annex 1 and should be read as part of this statement.
We focus on the strategic choices made in the Local Plan to go for development of new settlements and, specifically, the decision to locate major housing developments in the A428 corridor.
Matter 7A (i): Are all essential transport schemes/improvements identified in the Plans and is it clear how they will be delivered?
In our view, all the essential transport schemes/improvements have not been identified in the Plans: An all-ways interchange at the A14/M11/A428 junction to enable A428 eastbound traffic to turn south on the M11 to the biomedical campus and research parks south of Cambridge (the main area of employment growth in the next 10-20 years) was not identified in the plan and it is unclear how it would be delivered, if it were. The one major scheme that was identified for the proposed West Cambourne and Bourn Airfield sites (a dedicated bus-link from Caxton Gibbett to Queen’s Road in Cambridge, with a park and ride scheme at or close to Bourn Airfield) is, in our view, not sufficient. It does not address the fact that most people living in Cambourne do not work in the centre of Cambridge and will continue to travel to work by car. The same is likely to be the case if West Cambourne and Bourn Airfield go ahead.
All-ways Interchange at A14/M11/A428 junction.
The proposed housing developments in the A428 corridor are not feasible in the absence of an all-ways interchange at Girton/Madingley, enabling A428 eastbound traffic to turn right onto the M11 to access the planned major centres of employment growth south of the City of Cambridge. This is especially the case given (i) housing developments in St Neots and (ii) the plan to dual the Black Cat roundabout to Caxton Gibbett section of the A428, both of which will increase traffic flows along the A428.
At the moment, the main way to get from the A428 to the M11 is by driving down the A1303 (Madingley Hill). This is currently gridlocked every morning and evening during peak periods, with cars taking – on average - 30-45 minutes to get from the A428 down the A1303 to the M11 during rush hours. Because of this, most drivers leave the A428 and travel south through
1 The Coalition of Parish Councils comprises: Arrington, Bourn, Caldecote, Cambourne, Caxton, Croxton, Elsworth, Eltisley, Eversdens, Hardwick, Knapwell, Longstowe, Madingley, Toft parish councils.
1 the villages of Comberton, Barton, Bourn, Hardwick and Coton to reach the M11. There are also increasingly long tail-backs through Barton village (on the A603 and B1046). It currently takes 10-15 minutes to travel the one mile through Barton (on the B1046/A603 or just on the A603). These delays are likely to get worse as a result of the proposed housing developments SCDC expects most of the employment growth in South Cambridgeshire to take place in the bio-technology clusters south of Cambridge. If the extra 9,000 houses planned for St Neots (in Huntingdon District Council), West Cambourne and Bourn Airfield are built, the thousands of extra cars wanting to reach the M11, each morning, will have to use small village roads. This will lead to further bottlenecks on these roads and make life in some villages intolerable. The solution to this problem would be to build an all-ways interchange at the A428/M11 junction, so that A428 corridor drivers do not need to use Madingley Hill or village roads to reach the M11 and their places of work. This proposal is conspicuously missing from the Highways Agency’s A14 plans and from the Local Plan. We thus consider the Local Plan to be unsound. We consulted the Highways Agency on this issue. It has not decided yet whether to include the Girton/Madingley all-ways interchange in its next round of route planning studies (2015- 2020). Under the most optimistic scenario, even if this is done, and the scheme is found to be cost effective, the earliest that it could be operational would be the late 2020s. The Cambourne-Cambridge dedicated bus-link proposed under the City Deal is inadequate The first batch of proposed City Deal schemes, published in January 2015, includes an indicative investment of £87.1 million to provide a busway/segregated bus route from Caxton Gibbett to Queen’s Road in Cambridge (City Deal schemes 5, 6 and 9). This is the equivalent of 59% of the total first batch City Deal expenditure of £147.1 million. If we assume that half the proposed City Deal investment (i.e. £43.55 million) is required to serve West Cambourne and Bourn Airfield and assume that the maximum number of 5850 houses is built (2350 in West Cambourne and 3,500 in Bourn Airfield) this is equivalent to an investment of public funds equivalent to £7,450 per new house. If this scheme would make it possible for most people from the new developments to get to work using sustainable transport, this might be considered a reasonable cost. But it will not do so. The proposed scheme would only be of use to the small number people working in the centre of Cambridge. It would be of no use to the majority of residents who will commute to work in the science and research parks north and south of Cambridge or in other places in the district. A dedicated buslink from Cambourne to the Queens Road in Cambridge, linked to more park and ride facilities, will not reduce traffic or congestion on the A1303 significantly because bus travel is an unattractive way for most people to travel to work. This is because the spatial pattern of employment in Cambridge and South Cambridgeshire is dispersed across the city and district. While the bus link may be attractive for people working in the centre of the city (e.g., in the university, retail or offices) most people in South Cambridgeshire work outside Cambridge city centre and because of this will still use their cars. Going by bus to these scattered locations would be difficult, slow and inconvenient.
2
Proposed conversion of the A428 to a single lane carriageway at the new A14 junction Another area of concern, which could affect the viability of proposed developments in the A428 corridor is the new A14/M11/A428 junction. Under the Highways Agency’s plans, the A428 would be reduced from the current two lanes to one lane2 to take it round the new junction before joining the A14 eastbound (to the science and research parks north of Cambridge). It is highly likely that this also would become seriously congested in peak hours. Matter 7A (ii): Do the Plans adequately reflect the Local Transport Plan (LTP) and the Transport Strategy for Cambridge and South Cambridgeshire (TSCSC)? This is a difficult question to answer because of the circular nature of the planning process used. The Local Plan argues that it is based on the LTP and TSCSC, while these transport documents appear to have been written to support and justify the proposals in the Local Plan. There is, in our view, a fundamental weakness in the planning process. SCDC made the mistake of starting the Local Plan process by inviting developers to come forward with proposed housing sites, rather than taking a strategic view of the needs of the district. It is now in the invidious position of trying to retrofit and crisis manage a situation which it, itself, has caused. In our view, the development of the Local Plan should have involved three steps (i) objectively assessing where future businesses and jobs will be located; (ii) siting housing strategically in areas close to jobs where sustainable transport to work (e.g. rail, bus, cycle and walking) is feasible and (iii) planning the transport improvements necessary to cater for the emerging spatial pattern of economic and housing proposed. If this had been done, we would now have a Local Plan that was fit for purpose. Matter 7A (iii) Does the Transport evidence base comply with paras 54-001-20141010 and 54-011-20141010 of Planning Practice Guidance? In our view, the transport evidence base put in the public domain by Cambridgeshire County Council (CCC) is totally inadequate. We spent time with CCC trying to obtain the data and analyses on which critical statements in the TSCSC are based but we were told they are not available. For example, the Local plan advocates large new settlements (e.g., West Cambourne and Bourn Airfield) rather than a more dispersed pattern of housing development across the district. This decision was based on analyses undertaken by CCC’s consultants (Atkins) on the relative sustainability of these strategies in terms of transport (e.g., car trips generated). When we asked for the Atkins analysis underlying the decision to support schemes like Bourn Airfield we were told that the analysis had not been written up and no report as available. Similarly, it seems that, in preparing the Local Plan and TSCSC, no attempt was made to carry out a detailed journey-to-work analysis of Cambourne. Neither the district or county councils have recent detailed data showing (i) specific places where Cambourne residents work, (ii) how they get to work (bus, car or bike) and (iii) how long this takes. Without this information. It is hard to see how the Local Plan could advocate for new housing development in the Cambourne area.
2 The proposal is for a two-lane ‘hatched’ road round the new junction, on which the traffic would be reduced to one lane by cross-hatching on the road, to serve as a hard shoulder.
3
We decided to carry out our own traffic survey because we considered the transport evidence base on (i) traffic flows through our villages to be inadequate and (ii) the impact on bottlenecks on ‘rat-running’ through villages to be inadequate. Matter 7A (iv): Will the Plans encourage the use of sustainable modes of transport?
In our view the proposals in the Local Plan to develop two new housing developments in the A428 corridor (West Cambourne and Bourn Airfield) will not encourage the use of sustainable modes of transport. On the contrary, West Cambourne and Bourn Airfield schemes will encourage the use of non-sustainable modes of transport (cars).
Most people living in the new A428 corridor housing developments are likely to work in the main centres of employment growth south and north of the City of Cambridge. The proposed dedicated busway to central Cambridge will not be of use to these people in getting to work. They will have to use their cars.
Moreover, car journeys to work from West Cambourne and Bourn Airfield will be long (c. 25-30 miles round trip). The Cambridge and South Cambridgeshire Sustainable Development Strategy forecasts that most of employment growth in South Cambridgeshire will happen to the south and north of Cambridge. Almost no new jobs are expected west of Cambridge, in the A428 corridor.
The nearest railway stations to the proposed developments are 10 miles away at St Neots and Royston, the guided busway is more than 6 miles from Bourn Airfield and cycling to work is not an option, since it will take over an hour each way.
Given that the Local Plan aims to encourage the use of sustainable modes of transport, we find it difficult to understand how SCDC could propose housing developments in the A428 corridor.
In our opinion, the Local Plan does not encourage the use of sustainable modes of transport. 1. The proposed major new housing developments in the A428 corridor are located too far away from jobs (and centres of shopping, leisure, education and entertainment).
The National Planning Policy Framework (NPPF), paragraph 37 states: Planning policies should aim for a balance of land uses within their area so that people can be encouraged to minimise journey lengths for employment, shopping, leisure, education and other activities. Cambridge and South Cambridgeshire is one of the fastest growing regions in the UK. This growth is being driven by hi-tech industries (IT and bio-technology), which are concentrated in the City of Cambridge and in science parks to the north and south of the city in South Cambridgeshire. Approximately 75,000 people currently work in South Cambridgeshire, of which 20,175 (27% of the total) work in hi-tech industries. The spatial concentration of employment is likely to continue in the future. The 2012 Cambridge and South Cambridgeshire Sustainable Development Strategy3 identifies 18 major employment locations within
3 Cambridge and South Cambridgeshire Sustainability Strategy, prepared by the Cambridgeshire and Peterborough Joint Strategic planning Unit, 2012.
4
South Cambridgeshire. The biggest increases in jobs are expected where the jobs currently are - to the north and south/south-east of the City of Cambridge. Between 2011 and 2031, the total number of people employed in Cambridge and South Cambridgeshire is expected to grow by about 25% from approximately 175,000 to 220,000. Of the additional 45,000 jobs over 80% are expected to come in: (i) areas to the north and northwest of Cambridge, centred on the Cambridge Science Park and Cambridge Research Park; and (ii) to the south and southeast of the city, especially the biomedical campus at Addenbrooke’s.4 Only 2,800 new jobs (6% of the total) are expected in the A428 corridor. These new jobs in the A428 corridor will be offset by the loss of 1,600 jobs from the area, in 2016, when Papworth Hospital - one of the biggest employers in the west of the district – moves to the new biomedical campus at Addenbrooke’s Hospital (to the south of Cambridge). As a result only 1,200 new jobs are expected in the western part of the district. Why build houses where there are no jobs? In the period up to 2031 (and beyond), the main centres of employment, education and entertainment will continue to be found in Cambridge and areas south and north of the city to the east of the M11. It is unsound to locate major housing developments in the A428 corridor since this will increase journey lengths, compared to developments closer to Cambridge and to the south of the city. This is contrary to the NPPF. 2. The spatial pattern of development proposed in the Local Plan will result in unnecessary extra car journeys (compared to alternatives of building closer to Cambridge and nearer to jobs) and will impact significantly on carbon levels.
The NPPF, paragraph 30 states: Encouragement should be given to solutions which support reductions in greenhouse gas emissions and reduce congestion. In preparing Local Plans, local planning authorities should therefore support a pattern of development which, where reasonable to do so, facilitates the use of sustainable modes of transport. As was noted above, the SCDC Local Plan does not support a pattern of development that facilitates the use of sustainable modes of transport or which seeks to encourage solutions that support reductions in greenhouse gas emissions and reduce congestion. The proposed A428 corridor development of over 5,000 houses, for example, would be located over 10 miles away from a railways station, six miles from the busway and while it should be possible to improve bus services into Cambridge it is highly unlikely that sustainable and frequent bus services to other parts of the district would be viable. (Currently, over 75% of people in Cambourne commute by car and only 5% by bus. They also travel further to work than people in other parts of the district5). The A428 corridor developments, if they go ahead, would add 2500 tonnes of CO2 per year which represents 0.5 tonnes per new household. To put this in context, this is the equivalent of 10% of the average CO2 emission per UK household per year of 5 tonnes6. Detailed calculations are given in Annex 2.
4 The Sustainability Strategy estimates 19,700 new jobs to the north (44%) and 16,700 to the south (37%). 5 Living in Camborne. Cambridgeshire County Council, 2006. 6 Department of Energy and Climate Change United Kingdom housing energy fact file 2012. It is decreasing by 1.2% annually.
5
This is totally unnecessary and could be avoided if new housing is developed in areas:
close to main centres of employment, where most of the growth in employment in the next 10-20 years is expected to take place; and where it is possible for people to get to work using high quality public transport (e.g., trains, busway, bus services) or by cycling and walking.
This would be consistent with the National Planning Policy Framework (paragraphs 30 and 37). Such areas might include: the northern fringe of Cambridge and neighbouring areas of South Cambridgeshire (e.g., Waterbeach); and the southern fringe of Cambridge and neighbouring areas of South Cambridgeshire (e.g., Fulbourn and the Duxford/Hinxworth and the surrounding area). These two areas are expected to account for 80% of the growth in employment in Cambridge and South Cambridgeshire over the next 10+ years. Although development in the southern fringe of Cambridge might involve taking land from the green belt, this is permissible, where strong arguments on sustainable development can be made.
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ANNEX 1 Coalition of Parish Councils Traffic Survey
Introduction 1. The Coalition of Parish Councils undertook a traffic survey to assess current morning rush-hour traffic flows through the villages in the A428-A603 corridor west of Cambridge. We surveyed traffic at over 70 different sites, mostly in Late September and October 2014. The surveys were undertaken by trained volunteers. We surveyed at each site on either one or two days. We also recorded queuing times at key bottlenecks. 2. The survey methodology was designed by a specialist Transport Consultant7. We followed Department for Transport (DfT) guidance on traffic surveys. We carried out the surveys from 07.15 to 09.15 on either a Tuesday, Wednesday or Thursday morning in what the DfT considers ‘normal’ months for traffic surveys. We distinguished between (i) cars, motorbikes and light goods vehicles and (ii) heavy goods vehicles and buses, but, in this analysis we present data of combined flows. 3. The results of the traffic survey are shown on the map at Figure 1. Figures are rounded to the nearest 50 vehicles, unless otherwise stated. Key Findings 4. The main findings of the traffic survey are summarised in this section. 5. Heaviest traffic flows. The heaviest traffic flows were on the A 428 eastbound, on the A603 eastbound just before the M11, on the B1046 between Comberton and the A 603 and on Madingley Hill eastbound. These are show in Table 1. Table 1. Heaviest traffic flows
2 hourly flow Road Average hourly flow (07.15-09.15) A428 1 A428 eastbound just east of Caxton 3,100 1,550 Gibbett 2 A428 eastbound just before the 4,300 2,150 A1303 sliproad A603/B1046 3 B1046 between Comberton and the 1,300 650 A603 at Barton 4 A 603 eastbound, just before the 2,700 1,350 M11 A1303 – Madingley Hill 5 A1303 Madingley Hill just east of 1,550 775 the Coton turn 6 A1303 Madingley Hill eastbound 2,050 1,025 just east of the M11
7 Karl von Weber of LvW Highways Ltd.
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6. Traffic congestion. The heaviest traffic congestion is on the A1303 Madingley Hill and the A603/B1046 at Barton. It currently takes:
Madingley Hill: 30-45 minutes to complete the 2.4 km (1.5 miles) from the Madingley Mulch roundabout to the M11 in the peak morning rush hours; Barton: 10-15 minutes to complete the 1.8 km (1.1 miles) through Barton on either the A603 or the B1046/A603 to the roundabout just east of the M11 during the peak morning rush hours. 7. Traffic diversions caused by inadequate infrastructure. There are two major infrastructure constraints in the area. These are:
The lack of an all-ways interchange at the A14/M11/A428 junction, which means that eastbound traffic on the A428 (e.g., from the direction of St Neots and Cambourne) heading for the Biomedical Campus and other research parks south of the City cannot turn south on the M11. It thus has to leave the A428 at the Madingley Mulch roundabout and travel down Long Road to Comberton to join the B1046 to Barton and the A603 to get onto the M11, or travel through Grantchester, to the Biomedical Campus; The A1303 from the A428 to the M11 (Madingley Hill), which has severely limited capacity, resulting in long queues in the morning rush hours. As a result, motorists try to avoid the area by: o Queue jumping by ‘rat running’ through Madingley village to get onto the A1303 lower down, closer to the M11. Some 500 cars each morning do this (250/hour); o Avoiding the A1303 by driving south via Long Road to Comberton and then the B1046 to Barton in order to enter Cambridge or to the biomedical campus and other research parks south of the City. Approximately 90% of cars travelling down the A1303 (Madingley Hill) go into Cambridge. Only 10% turn right onto the M11. 8. Currently 900 cars (450/hour) travel down Long Road from Madingley Mulch roundabout to Comberton and the B1046. In Barton, 1300 cars (650/hour) from the B1046 join the A603 eastbound, giving a total flow just before the M11 of 2,700 vehicles (1,350/hour). Other vehicles also join from other directions, at the roundabout east of the M11. Of the total combined flow, 1,200 (600/hour) go into Cambridge, 900 (450/hour) drive through Grantchester and 800 join the M11 southbound, mostly heading towards the biomedical campus. This flow is shown in red in Figure 2.
Figure 2: Route taken by traffic using Long Road to avoid Madingley Hill
A428
M11 Madingley
Mulch Long Road CAMBRIDGE A603
Comberton Barton
B1046 B1046 Grantchester
Biomedical A603 campus
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9. Traffic flow through villages. The need to find alternative routes to overcome the problem of inadequate infrastructure results in high traffic flows through many villages in the area. All villages report a significant increase in traffic over the last 5-10 years and in some villages the traffic is becoming intolerable. 10. The villages with the highest flows of through traffic are shown in the table below8. This shows the number of vehicles driving through each village from all directions. Since Comberton and Barton are both affected by two different streams of traffic, we have presented these separately.
Village Two hourly flow Average hourly (07.15-09.15) flow Barton (A603) 2,300 1,150 Barton (B1046) 1,700 850 Comberton (B1046) 1,200 600 Comberton (Long Road) 1,200 600 Longstowe/Arrington 1,600 800 Toft 1,250 625 Elsworth 1,100 550 Dry Drayton 1,050 525 Madingley 800 400 Caxton 700 350 Bourn 600 300 Coton 450 225 Hardwick 450 225 Knapwell 400 200 Eversden 350 175
11. Elsworth and Dry Drayton through traffic is mainly travelling from the A14 to the A428, with some of it going onto the A603 and south Cambridge. The Madingley through traffic is mainly traffic trying to save time by joining the A1303 lower down Madingley Hill, close to the M11. Implications 12. The proposed housing developments in the A428 corridor (e.g., West Cambourne and Bourn Airfield) will significantly exacerbate the current congestion and traffic flows through villages in the area. We estimate, from our traffic survey, that of the 1,800 cars (900/hour) from Cambourne, which join the A428 eastbound or the old A428 road, at least 500 (250/hour) cut down Long Road or through the villages to get to Barton and the M11. 13. The proposed West Cambourne and Bourn Airfield developments (a total of approximately 5,850 new houses (compared to the current Cambourne total of 4,400 houses) would thus increase traffic on the B1046 and A603 by a minimum by 650 new cars (325/hour). Given that the Cambridge and South Cambridgeshire Sustainable Development Strategy estimates that there will be an extra 10,500 jobs over the next decade on the biomedical campus and nearby research parks this is almost certainly a significant underestimate. It can be safely assumed, if West Cambourne and Bourn Airfield go ahead,
8 This was estimated from the balance of traffic entering and leaving each village.
10 that a greater proportion of people in are likely to commute to work in the Biomedical campus and nearby facilities. 14. Add to this a general increase in traffic heading eastbound towards the new employment opportunities via the A603 and B1046, the queues at Barton are bound to get longer. Tailbacks of 30-45 minute, comparable to Madingley Hill today, are likely. Cambourne commuters also leave the settlement to the South and join the A1198 southbound. Of the 800 vehicles (400/hour) travelling south on the A1198 through Longstowe we estimate 250 (125/hour) come from Cambourne. If West Cambourne and Bourn Airfield go ahead, this figure would probably more than double. 15. In our view, rather than building more houses in the A428 corridor, new housing developments should focus on areas in the south of the City and contiguous parts of South Cambridgeshire. There are three reasons for this:
these locations are close to the new employment opportunities in the Biomedical campus (e.g., Papworth Hospital, Astra-Zenica and the nearby research parks); a denser population in this area would make an efficient and frequent bus service in the area feasible and make it possible for people to cycle and walk to work, thus supporting the planning policy of sustainable transport; and this would reduce the need to travel the 10-15 miles from the A428 housing developments, reducing adverse effects on carbon emissions and climate change, also supporting more sustainable development. The infrastructure developments proposed under the City Deal are inadequate. 16. The first batch of proposed City Deal schemes includes an indicative investment of £87.1 million to provide a busway/segregated bus route from Caxton Gibbett to Queen’s Road in Cambridge (schemes 5, 6 and 9). This is the equivalent of 59% of the total first batch City Deal expenditure of £147.1 million. 17. In our view this is an attempt by SCDC to mitigate its own planning mistakes proposed in the Local Plan – specifically West Cambourne and Bourn Airfield developments. If one assumes that half the proposed cost is for these two developments (i.e. £43.55 million) and that the maximum number of 5550 houses are built (2350 in West Cambourne and 3,200 in Bourn Airfield) this is equivalent to an investment of public funds equivalent to £7,850 per house. 18. If this investment made it possible to get people from the new developments to work using sustainable transport, this might be considered a reasonable cost. But it will not do so. 19. A dedicated buslink from Cambourne to the Queens Road in Cambridge, linked to more park and ride facilities, will not reduce traffic or congestion on the A1303 significantly because bus travel is an unattractive way for most people to travel to work. 20. The spatial pattern of employment in Cambridge and South Cambridgeshire is dispersed across the city and district. While the bus link may be attractive for people working in the centre of the city (e.g., in the university, retail or offices) most people in Cambridge and South Cambridgeshire work outside the city centre and will still use their cars. 21. The only way in which housing developments in the A428 could possibly be made more viable would be by constructing an all-ways interchange at the A14/M11/A428 junction, enabling eastbound traffic on the A428 to turn south on the M11. The Highways Agency has
11 considered an all-ways interchange at Girton/Madingley (A14, A428, M11) but, due to the high cost and other priorities, no planning/design studies have yet been undertaken. If a study were undertaken in 2015-20 and it proved cost-effective, the earliest the interchange could be operational is the late 2020s. This is far too late given the developments in St Neots (Love’s Farm) and the proposed timing of West Cambourne and possibly Bourn Airfield. 22. In future, congestion is likely also increase on the A428 itself as the current two lane eastbound carriageway is reduced to one lane at the remodelled A14/M11/A428 junction.
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Annex 2
Additional CO2 emissions from commuting
According to the 2011 census there were 0.998 commuting car journeys per dwelling in the Bourn ward [1]. Based on this figure, an additional 4989 commuting car journeys will be generated by building 5000 extra houses in the area.
Assuming the provision of bus services has a similar effect on car journeys in the corridor as it did when they were provided as part of the Cambourne development (10% reduction) this will equate to an additional 4092 commuting car journeys in the area.
On average residents of the Bourn ward work 213 days per year [2] and it has been shown that Cambourne residents travel an additional 10 km travel to work than the rest of South Cambs [3]. Assuming the residents of the new developments follow a similar work pattern, these figures combined with the additional commutes means that there will be 4260 km travelled each year by new residents of the West Cambourne and Bourn Airfield developments as a consequence of the developments being further from the main areas of employment in the region.
Assuming the new residents all have cars no older than 5 years (unlikely seeing as the “affordable housing” argument is being pushed) this will lead to an additional carbon footprint of 2,521 tonnes per year. Even if their bus plans achieve a 20% reduction in commuting car journeys, there will still be 1969 tonnes of carbon emissions generated each year by the extra 10km residents have to travel to work.
Notes
[1]. Living In Cambourne, Cambridgeshire County Council, 2006. [2]. http://ukcensusdata.com [3]. DfT Traffic Counts
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Bourn Parish Council response – 17th February 2015
I am writing on behalf of Bourn Parish Council to object to the proposed West Cambourne development because of the adverse impact of higher traffic flows on Bourn and other local villages.
Bourn Parish Council recently undertook a traffic survey in the area bounded by the A1998, A428, M11 and A603, including Cambourne. This was undertaken on behalf of a Coalition of 14 Parish Councils and was submitted to the Planning Inspector as part of the Examination in Public of the South Cambs Local Plan. (See attachment).
We found that at total of 2,491 vehicles left Cambourne in peak morning period (0715 to 0915) – approximately 1,245/hour. Of these 1,045.hour travelled out of Cambourne to the north and 200/hour of the south-west to join the A428 Cambourne currently has approximately 4,000 occupied houses. If we assume the same level of trips will be generated by West Cambourne residents and 2,350 homes are built, the total traffic outflow from Cambourne will increase by approximately 731 vehicles/hour to 1,976 vehicles/hour.
Most of these vehlcles head east on the A428 (or the old A428 road) heading for the high tech employment centres north and south of the city. Because it is not possible to turn from the A428 eastbound onto the M11 southbound, most of these vehicles have to ‘rat run’ through villages to get to the A63/M11 junction east of Barton, which causes high levels of traffic and jams on Long road Comberton, in Barton, in Madingley and in other villages, including Bourn.
The Cambridge and South Cambridgeshire Sustainability Strategy estimates that, over the next 20 years, most of the new jobs in the Cambridge region, will be south of the city in the biomedical park and surrounding facilities. This will increase further traffic flows through the villages from West Cambourne and similar developments.
Bourn Parish Council considers that the proposed West Camboune development should not be approved unless an all-ways interchange is built at the at A14/A428/M11 junction. The Highways Agency indicates that this is unlikely until the late 2020s, if at all. Caldecote Parish Council 06/02/2015 Please find attached the recommendation from Caldecote Parish Council in respect of the Cambourne West application.
Comments are as follows:
The Parish Council agree in principle to the application for up to 2350 residential units but would wish to see planning conditions in place that ensure the development of the associated infrastructure is phased in such a way as to keep up with the development of dwellings.
Regards
Simon Crocker Parish Clerk and Responsible financial Officer Caldecote Parish Council
c/o Revd Alison Myers Area Mission Partnership The Rectory, 50, Main Street Hardwick, Cambridge, CB23 7QS [email protected] 01954 212815
Mr Edward Durrant 28 February 2015 The Planning Department, South Cambridgeshire District Council
Dear Mr Durrant,
Planning for the provision of community and church meeting space in Cambourne West
We write on behalf of the Area Mission Partnership and Cambourne Church in connection with the planning consultation regarding application S/290/14/OL. The Area Mission Partnership is a joint planning body of Cambourne Church, the Papworth Team Ministry1 and the Lordsbridge Team Churches2. It works in collaboration with wider church bodies including the Local Advisory Group3 and the Diocese of Ely. As such we represent all the main Christian denominations in the area.
A Christian presence and community cohesion
Experience has shown that a Christian presence, committed to working in and for a local community, can be of huge benefit in that community’s development. Since the beginnings of Cambourne, the local church has been welcomed with other agencies as a valued partner in the joint task of fostering community. The church has further demonstrated practical and ongoing commitment to the community by the collaborative funding of posts in the areas of children’s, youth and families work.
Cambourne Church submitted an expression of interest which was included in the Parish Council’s 106 submission for the planning consultation. Recognising the above, that submission asked for a proportion of the 106 money to fund the necessary expansion of Cambourne Church Centre to cater for the enlarged Cambourne community.
Since then we have been continuing to consider how a church presence in Cambourne West itself might add value to the entire community.
1 13 villages (and Anglican parishes) including Bourn, and to the west, Caxton, Elsworth and Papworth. 2 11 villages (and Anglican parishes) east of Cambourne including Hardwick, Caldecote, and Comberton. 3 part of the Cambridgeshire Ecumenical Council, and representing the Methodist, Baptist, Catholic, United Reformed, Roman Catholic and Anglican Churches.
We see the following challenges for creating community cohesion in Cambourne West:
In the early phases, starting from the furthest corner of the site and with access on the Caxton side, links between newcomers and the rest of the Cambourne community will be difficult to make and maintain.
Unless there are suitable places for locally based community activities from as early as possible, we will lose the impetus that the first arrivals will bring to build cohesion amongst their new neighbours.
With Cambourne West being somewhat separate from the rest of Cambourne, it will be hard for Cambourne Church to make use of its track record in fostering community, and in linking Cambourne West into the wider Cambourne community, unless it has a local meeting place. This will also be true of other bodies with the same aims.
We propose that two ideas are explored. We recognise that these ideas will require further thinking and conversation with other partners, however, we would like to offer them as mutually valuable ways forward in the joint aim of creating a cohesive community which people want to join and in which they want to put down roots.
1. A community house
We suggest the design and build of a ‘community house’ as part of the first phase of development. This will enable two things:
Great Cambourne benefitted greatly from the early building of Church House in Broad Street for a resident minister to live ‘on site’. It is envisaged that the family who lives in a similar house in Cambourne West, whilst not being fully employed (or employed at all) by the church, would do so in order to work at developing the wider community as well as the Christian community in the new village. They would also represent Cambourne Church and its community activities in that locality, thus enabling connections to be made from Cambourne West into the rest of Cambourne.
Further, if this house was built with large enough reception rooms for community gatherings it could function as a first base for small community groups, such as parents’ and toddlers or hobby groups, as well as for Christian worship in the early stages of building. Experience in the earliest phases of Lower and Great Cambourne was that providing a place for the first small groups to meet was vital in fostering community, with the church’s portacabin – the Ark – playing a key role.
This particular solution to fostering community from the earliest days, recognising the value of small group space and church/community workers on site, is being used in new housing outside Ely. The Church of England’s Pioneer Minister programme encourages this community based approach.
2. Community space in the first school
We also suggest the creation of shared community space in one of the primary schools. This could take the form of a ‘community room’ attached to the school.
Experience has shown that because of the young demographic in Cambourne – likely to be repeated in Cambourne West – the schools quickly become community hubs. Local community space based in a school will recognise, and make the most of, the importance of families in building community. We see two ways in which this might work:
If the school is a Church School then the link between school and church could underpin the design and provision of such a shared space - we understand that this approach is being explored in another new Cambridgeshire development.
If the school is a community school, then we suggest adapting the model used for the community room built as part of Hardwick community primary school when the village expanded considerably with new housing in the late 1980s. We would be prepared to discuss how the church could help manage such a community space.
In summary
We believe that these two ideas - a ‘community house’ for a resident church/community worker from the earliest days, and shared community space in one of the primary schools as the village grows - would go a long way towards facilitating the building of a flourishing and healthy community. Of course, we appreciate that there will need to be further discussions with the planners, builders and other bodies both over the design and the funding of these projects.
We would like at this stage to register our interest in discussing further both suggestions with planners, builders and other appropriate bodies.
Yours faithfully,
Revd Alison Myers, on behalf of the Area Mission Partnership Revd Matthew Trick, on behalf of Cambourne Church cc: Revd Peter Wood, Director of Mission, Ely Diocese Revd Mike Booker, Chair of the Local Advisory Group
February 19, 2015
BY EMAIL
Edward Durrant [email protected] Cambridge Cycling Campaign Llandaff Chambers, 2 Regent Street Cambridge CB2 1AX 01223 690718 [email protected]
www.camcycle.org.uk registered charity no. 1138098
Dear Edward Durrant,
Cambourne Expansion Planning Reference S/2903/14/OL
Cambridge Cycling Campaign works for better, safer and more cycling in and around Cambridge and has over 1,100 paid members. We scrutinise planning applications and proposals to assess whether they will facilitate safer cycling and encourage more people to cycle. Our response to proposals is based on such assessment.
Summary
The SCDC emerging policy states amongst the design and access requirements “high quality pedestrian and cycle routes through the site”. Additionally, the National Planning Policy Framework states the importance of
Promoting sustainable transport Promoting healthy communities
The current design and access statement does not meet these criteria. Existing cycling access within and outside Cambourne is poor, resulting in low levels of cycling compared to other towns and villages in South Cambridgeshire. The proposals do not significantly improve cycling connections outside Cambourne, and continue the current poor quality provision within Cambourne. In such conditions walking and cycling for transport will be low, and the health benefits of active transport will not be realised. Existing modal share shows that two-thirds of local journeys are driven, despite the short distances involved.
No distinction has been made between walking and cycling in the proposals, with routes shared. Unsegregated shared-use provision is poor for both walking and cycling, creating conflict between users. The problems of poor shared-use are described at http://www.camcycle.org.uk/newsletters/111/article11.html
The suggested reasonable maximum cycling distance of 5km is less than current average cycle to work distance surveyed by Travel For Cambridgeshire of over 5.5km, let alone the
For better, safer and more cycling in and around Cambridg e Cambridge Cycling Campaign 2 longer distances that people are willing to cycle. Such low aspirations inevitably result in poor proposals, as the need for continuous and direct cycling routes is underestimated.
Quality of network within Cambourne
The access document states that “Primacy has been given to walking, cycling and community transport”, but diagrams show winding paths which do not meet walking and cycling desire lines, and requirement to give way to motor traffic even on minor residential roads. This means interrupted trips via active transport in favour of continuous trips by private car, the reverse of the claimed hierarchy.
The design documents refer to “on and off-road segregated routes”, but this terminology has been mis-applied. Segregated cycle routes are, crucially, separated from both motor traffic and pedestrians, but none are proposed.
Cycling access outside of Cambourne
Cambourne is surrounded by A-roads which are entirely unsuited to cycling due to speed and volume of traffic. Other road connections are on rural roads, which have the highest collision rates of all types of road for all users, and the results of collision at speed are likely to be fatal for someone on foot or bike.
Where there are off-road connections they are narrow and right next to the carriageway, where noise and air pollution levels are high. Other connections are unsurfaced bridleways, unsuitable for the majority of bikes all-year and all-weather, and for travelling any distance for transport.
Proposals to improve the St Neots Road address only driver awareness, and as such are totally inadequate either as a safety intervention or to encourage cycling. Without infrastructure to separate people on bikes from high speed motor vehicles cycling levels will remain low.
Potential contribution to improvements for routes to Caxton, Papworth Everard, Bourne, Knapwell and Elsworth are described as “predominantly leisure routes” in Appendix 9.1A. We take this to mean it is expected to be of too poor quality for transport trips, continuing the dependence of the residents of Cambourne on inactive travel, and the associated health, pollution and congestion impacts.
Spine Road
The design and access document describes how the spine road will be routed through the community hub and through green space. It is entirely inappropriate to have a spine road through a community hub, even with traffic calming. The volumes of traffic will make it hard to cross roads irrespective of speed, and pedestrians defer to motor vehicles in such circumstances. In this respect experiments in shared-paving in Poynton and Exhibition Road have failed: only where there is no through-route for motor traffic can a semi-pedestrianised area succeed. The route as proposed will be noisy and unnecessarily polluted, which will discourage relaxed browsing of shops and active transport, and the café culture desired.
Cambridge Cycling Campaign 3
Likewise the ability to enjoy the central green spine will be impaired by routing the main road through it, as well as affecting local wildlife and plant species.
Conclusion
Current proposals to expand Cambourne continue the mistakes of the original development in making walking and cycling less convenient and pleasant than using a private car. The combining of all walking and cycling routes disadvantages both modes of transport, as can already be seen in the existing low modal share for active transport in Cambourne.
Our Guide, Making Space For Cycling http://www.makingspaceforcycling.org/ has been endorsed by all national cycling organisations and outlines the kind of high quality cycle infrastructure we expect from a new development seeking to promote health and sustainability through supporting cycling.
Well designed walking and cycling routes, suitable for a wide variety of utility trips, such as school, shopping or work, can provide a good alternative to many private car trips, even those greater than 5km, but only if all kinds of people can feel their trip is safe, convenient, and not mixed with other types of user.
Yours sincerely, on behalf of Cambridge Cycling Campaign,
Hester Wells
Cambridgeshire County Council Officer Comments on land West of Cambourne Planning Application (S/2903/14/OL).
Set out below are officer comments from various County Council service teams. These comments have not been approved by Members. They will be considered by Members at the 21st April Economy & Environment Committee.
The planning application seeks approval for 2,350 dwellings; retail, use classes A1- A5; offices/light industry, use class B1; community and leisure facilities, use class D1 and D2; Two primary schools and one secondary school, use D1; three vehicular access points and associated infrastructure.
1.0 EDUCATION
1.1 Full comments on education provision are set out in appendix 1 of this note, however, subject to the below matters of detail being addressed or clarified there is no objection to the planning application on education grounds.
1.2 Matters of detail that will need to be addressed as part of the outline planning application process of by way of planning condition or Section106 agreement:
The contours at the school site in the western part of the development to be at a noticeable gradient. It will be a requirement of the Section106 agreement for this site to be flat and confirmation should be sought from the applicants that this can be achieved prior to the determination of the application. The maximum heights of the school buildings are set as 12 metres. To give the flexibility required at detailed design stage, it is considered that this should be increased to 15 metres. The renewable energy statement contains a series of potential recommendations for the schools. Unless the applicants are willing to fund the provision of increased renewable energy within the school sites as part of the Section106 agreement, it is unreasonable for the school buildings to provide a higher level of renewable energy than that required by policy. Early Years and Childcare Facilities will be required at the primary school sites
2.0 LIBRARIES AND LIFELONG LEARNING
2.1 An expansion of the existing library at Cambourne is not proposed in the planning application although an expansion to the co-located health provision is.
2.2 The library in Cambourne was opened in 2004 and at present serves a population of over 6,500 people. There are currently Section106 monies available to modify the library to serve another 2,442 residents (arising from the Cambourne 950 development). A potential influx of another 6,345 residents as a result of this development proposal on library provision will require further enhancements to the existing facility to ensure it can deliver a good service to the additional population.
2.3 The existing library is approximately 1 mile away from this proposed development so officers confirm that there is no requirement to provide a presence within the development site boundary. The existing library is ideally situated near the centre of the Cambourne villages and main retail area.
Section 106 Contribution
2.4 Provision for enhanced static library provision (resources and fit out) with no physical changes to existing building.
2.5 Financial contribution £42.12 per head of population increase. This figure is based on the fit out costs in the MLA document: Public Libraries, Archives and New Development: A Standard Charge Approach, May 2010.
3.0 PLANNING, MINERALS AND WASTE& WASTE STRATEGIC PROJECTS (as WASTE PLANNING AUTHORITY (WPA) AND WASTE DISPOSAL PLANNING AUTHORITY (WDPA)).
Planning Statement and Design & Access (D&A) Statement
3.1 The policy review in the Planning Statement, and the overview within the D&A statement, omit any mention of the adopted Cambridgeshire and Peterborough Minerals and Waste Core Strategy (July 2011) and the linked RECAP Waste Management Design Guide SPD (February 2012) that form part of the adopted development plan. Both have policies and guidance which are directly relevant to waste planning and which need to be reflected in the development’s Construction Environmental Management Plan (CEMP) and the Waste Strategy (including Site Waste Management Plan) going forward. This is particularly important for both the construction and operational phases of the development, as at present the planning statement and D&A statement focus on the occupational phases. Whilst we appreciate that consideration of the construction phases of the development and the adopted waste planning policy documents have been touched upon within the Environmental Statement, waste issues and planning policies need to be fully reflected to ensure that the overall impact of the development is considered from the outset in its entirety.
3.2 Paragraph 5.51 of the Planning Statement discusses compliance with South Cambs Policy T1/8 and confirms that contributions will be secured via planning obligations and / or Community Infrastructure Levy (CIL). As this is a strategic site that will have an impact on the household recycling centres, and therefore the strategic waste ‘service’ provided for the new residents, we would expect this development to make a contribution to strategic waste infrastructure in line with adopted Minerals and Waste Core Strategy Policies CS16 and CS28 and the linked RECAP Waste Management Design Guide Supplementary Planning Document (SPD), as discussed further below.
3.3 The D&A includes ‘Community Infrastructure’ under the sustainable development section of the document on page 100. This notes that ‘Waste and recycling facilities’ may be included. However, reference to strategic waste and the guidance set out in the RECAP Waste Management Design Guide SPD is not included within this document or within the draft Heads of Terms document. The requirements set out within the RECAP Waste Management Design Guide SPD need to be addressed.
3.4 Although there is no specific reference to the RECAP Waste Management Design Guide SPD within the D&A, we welcome the section on ‘Waste & Recycling’ on Page 102 which refers to the house design and layout allowing for the storage of waste and recycling bins to be submitted at the reserved matters stage. We also note that the wheelie bin locations will not be further than 20 metres away from the adopted highway and the layout of individual plots must ensure that wheelie bins can be easily moved from their day to day location to their collection point. Although we appreciate where wheelie bins are required to move through their garages adequate space in the width of garages needs to be designed, as stated within this section, we would suggest that this is not ideal for new developments. Appropriate space needs to be designed in at an early stage to avoid such a solution. These requirements can be secured by planning condition.
3.5 We note that the phasing strategy shown on Page 104 of the D&A considers the routes for construction traffic and ensures that these routes are kept separate from visitor and residential routes at all times. This acknowledgement is welcomed and further detail and movement numbers will need to be assessed at the reserved matters stage. This information can be secured by planning condition (see below).
Environmental Statement (ES)
3.6 Chapter 15 of the ES considers the ‘Waste Effects’ that are likely to result from the Cambourne West application. This takes account of predicted waste arisings during the construction phase, and the occupation phase of the completed Development. We welcome the inclusion of predicted quantities of individual waste arisings and their proposed waste management options within the Site Waste Management Plan (SWMP) shown in Appendix 15.1. We also welcome reference to the Cambridgeshire and Peterborough Minerals and Waste Core Strategy Development Plan Document (2011) and the requirements within it that need to be met. Particularly that Mineral and Waste Core Strategy Policy CS16 requires new development to contribute to the provision of Household Recycling Centres (HRCs) with an identified link to the RECAP Waste Management Design Guide SPD, and the requirement for the development to provide temporary waste management facilities, which will be in place throughout the construction of the development.
3.7 Chapter 15 of the ES considers the development in line with the Waste Hierarchy, where disposal should be considered as the last resort. This approach is welcomed, as is reference to as much of the materials being reused on site where possible. Whilst it is slightly unclear why the soils (excavated soil and topsoil, including material to be reinstated) are counted as ‘Non-Hazardous’ as opposed to ‘Inert’ in the consideration of the waste stream, we do welcome the statement in Paragraph 15.83 that states that the soils should be appropriate for reuse on site either as direct reinstatement, or for use in landscaping and bunds, or as low-grade fill material. However, whilst we welcome this approach, we are concerned that as approximately 90% of the Non-Hazardous waste stream assessed is soils (511,042 tonnes over the 12 year construction period), and the risk of contamination is raised, there does not appear to be an analysis of the impacts any contamination would make to the disposal rates off-site, and the impact that would have in terms of traffic movements and available waste facilities. More information in relation to the risks associated with the proposed earthworks needs to come forward for further consideration, along with anticipated construction traffic anticipated for both minerals and waste traffic, to allow a cumulative assessment to be made within the transport assessment for the development. This information can be secured by planning condition (see below).
3.8 Storage design in line with the RECAP Waste Management Design SPD has also been addressed in Paragraphs 15.141 to 15.152 of the ES. On the basis that this information will be used to inform the master planning of Cambourne West and that more detail will be provided at the reserved matters stage, we are content that the policy requirements can be met.
3.9 Chapter 9 of the ES acknowledges that the design of the roads serving the site has been completed to ensure that access can be completed by large vehicles. Furthermore, that provision will be made within the completed proposed development to ensure that the suitable street widths serving development are provided in order to accommodate refuse collection vehicles. More detail should come forward at the reserved matters application which should include swept path analysis in line with adopted waste planning policy and the related guidance set out in the RECAP Waste Management Design Guide SPD.
Suggested Conditions
1. Site Waste Management Plan and Waste Audit
3.10 Prior to the commencement of development a full Site Waste Management Plan and Waste Audit must be submitted in writing and approved by the Local Planning Authority. This shall include details of:
a) Construction waste infrastructure including a construction material recycling facility to be in place during all phases of construction; and details of how inert waste arisings will be managed / recycled during the construction stage; b) Anticipated nature and volumes of waste and measures to ensure the maximisation of the reuse of waste; c) Measures and protocols to ensure effective segregation of waste at source including waste sorting, storage, recovery and recycling facilities to ensure the maximisation of waste materials both for use within and outside the site; d) Any other steps to ensure the minimisation of waste during construction; e) The location and timing of provision of facilities pursuant to criteria a/b/c/d; f) Proposed monitoring and timing of submission of monitoring reports; g) The proposed timing of submission of a Waste Management Closure Report to demonstrate the effective implementation, management and monitoring of construction waste during the construction lifetime of the development; h) A RECAP Waste Management Guide toolkit, including a contributions assessment, shall be completed with supporting reference material; i) Proposals for the management of municipal waste generated during the occupation phase of the development, to include the design and provision of permanent facilities e.g. internal and external segregation and storage of recyclables, non-recyclables and compostable material; access to storage and collection points by users and waste collection vehicles is required.
3.11 The agreed Site Waste Management Plan shall be implemented.
Reason: To ensure that waste arising from the development is minimised and that which is produced is handled in such a way that maximises opportunities for re-use or recycling in accordance with Policy CS28 of the Cambridgeshire and Peterborough Minerals and Waste Core Strategy (2011) and Policy DP/6 of the South Cambridgeshire District Council Development Control Policies DPD (2007).
2. Construction Environmental Management Plan
3.12 A Construction Environmental Management Plan (CEMP) shall be submitted and approved for the development hereby permitted. The CEMP shall accord with and give effect to the waste management principles set out in the adopted Cambridgeshire & Peterborough Minerals and Waste Core Strategy (2011) and Waste Hierarchy.
3.13 The CEMP shall address the following aspects of construction:
a) A construction programme; b) Contractors’ access arrangements for vehicles, plant and personnel including the location of construction traffic routes to, from and within the site, details of their signing, monitoring and enforcement measures, along with location of parking for contractors and construction workers; c) Construction hours; d) Delivery times for construction purposes; e) Soil Management Strategy including a method statement for the stripping of top soil for re-use; the raising of land levels (if required); and arrangements (including height and location of stockpiles) for temporary topsoil and subsoil storage to BS3883:2007; f) Noise monitoring method including location, duration, frequency and reporting of results to the LPA in accordance with the provisions of BS 5228 (1997); g) Maximum noise mitigation levels for construction equipment, plant and vehicles; h) Vibration monitoring method including location, duration, frequency and reporting of results to the LPA in accordance with the provisions of BS 5228 (1997); i) Setting maximum vibration levels at sensitive receptors; j) Dust management and wheel washing measures to prevent the deposition of debris on the highway; k) Site lighting; l) Drainage control measures including the use of settling tanks, oil interceptors and bunds; m) Screening and hoarding details; n) Access and protection arrangements around the site for pedestrians, cyclists and other road users; o) Procedures for interference with public highways, (including public rights of way), permanent and temporary realignment, diversions and road closures; p) External safety and information signing and notices; q) Liaison, consultation and publicity arrangements including dedicated points of contact; r) Consideration of sensitive receptors; s) Prior notice and agreement procedures for works outside agreed limits; t) Complaints procedures, including complaints response procedures Membership of the Considerate Contractors Scheme; u) Location of Contractors compound and method of moving materials, plant and equipment around the site.
3.14 The Construction Environmental Management Plan shall be implemented in accordance with the agreed details, unless otherwise agreed in writing by the Local Planning Authority.
3.15 Reason: To ensure the environmental impact of the construction of the development is adequately mitigated and in the interests of the amenity of nearby residents/occupiers (District Council to insert policy references); and to comply with Guidance for Local Planning Authorities on Implementing Planning Requirements of the European Union Waste Framework Directive (2008/98/EC), Department for Communities and Local Government, December 2012. Section 106 Contribution
3.16 Infrastructure type: Strategic Waste – Household Recycling Service;
3.17 Requested obligation – Capital contribution from Cambourne West towards the cost of providing a household recycling service to serve the Cambourne West residents in line with adopted waste planning policy. Calculated on a per dwelling basis to support the household recycling service for the new residents of Cambourne West.
3.18 Project name – Household recycling service waste contribution;
3.19 Detail – For Cambourne West (based on 2,350 dwellings) a capital contribution of £425,350 is required in line with adopted waste planning policy, which is consistent with all growth sites around Cambridge. Costs are based on a per household basis on the catchment area for St Neots. The strategic waste contribution sought is for a financial contribution to the capacity already created and improvements to the service for the new residents. The requirement is based on a capital cost only which equates to £181 per dwelling, i.e. 2,350 dwellings X £181.00 per dwelling = £425,350.
4.0 ARCHAEOLOGY
4.1 Regarding the archaeological implications of the above development officers object to the planning application and recommend that permission is refused on the grounds that the impact of the development on heritage assets of archaeological significance has not been adequately assessed and that the requirements for mitigation of the impact cannot presently be defined.
4.2 Archaeological investigations undertaken during the development of Cambourne to the east demonstrated that this landscape was extensively and intensively settled and managed from the Middle Iron Age to the early Saxon period (Wessex Archaeology Report Number 23). Investigations in advance of improvements to the A428 adjacent to Cambourne also contributed to this understanding of the late prehistoric and Roman landscape (Albion Archaeology, EAA 123).
4.3 Surveys undertaken in support of the application (aerial photographic assessment and geophysical survey) indicate areas of settlement and related activity. Some of these appear to be very extensive in nature and likely continuous (AP5 and AP6). Others, such as the area of settlement identified as AP6 and the enclosures at AP4 give the impression of being contained. However, the fieldwork undertaken in advance of construction of the new school site demonstrated that features relating to these areas of settlement extend beyond the areas of visible cropmarks (HER ECB3735). The proximity to the major Roman road Ermine Street (HER 15034) increases the importance of the area and the potential for highly significant archaeology.
4.4 Swansley Wood Farm is a moated manor of medieval origin. Although excluded from the application area, this site is unlikely to have existed in isolation and additional evidence for medieval settlement and land use can be anticipated in the surrounding area.
4.5 The site of RAF Caxton Gibbet is located within the northern part of the site and evidence for this is recorded in the aerial photographic assessment. The site has heritage value in terms of Cambridgeshire’s role in the Second World war and should also be considered as a heritage asset.
4.6 There is therefore high potential for significant archaeology of Iron Age, Roman, Early Saxon, Medieval and modern date to survive in the proposed development area. Surface artefacts also suggest a Bronze Age presence in the landscape (HER 11874). The National Planning Policy Framework paragraph 128 state: In determining applications, local planning authorities should require an applicant to describe the significance of any heritage assets to be affected. In also states that Where a site on which development is proposed includes or has the potential to include heritage assets with archaeological interest, local planning authorities should require developers to submit an appropriate desk based assessment and, where necessary, a field evaluation. The Cambridgeshire Historic Environment Record and the applicant’s own assessment conclusively demonstrate the presence of assets with archaeological interest. Our understanding of the landscape strongly indicates that these will be more extensive than can be defined from aerial photographic and gesophysical surveys. Furthermore, there is potential for additional assets to be present which have not been responsive to the surveys undertaken to date. It is not possible to adequately assess the extent and significance of these heritage assets on the basis of information currently available.
4.7 The Environmental Statement suggests that it has not been possible to undertake fieldwalking or trial trenching surveys due to the agricultural crop cycle (13.112). However, we have been advising this approach for over a year, and issued a design brief for this work in March 2014. I find it difficult to believe that there has not been adequate opportunity to arrange fieldwork around the agricultural cycle within this time frame.
4.8 The Environmental Statement proposes trial trench evaluation as a mitigation strategy but goes on to suggest that mitigation will be developed subsequent to this (13.113). The ES goes on to suggest generic principles of preservation in situ or by record. We would not consider evaluation to be an appropriate mitigation response. Evaluation is intended to define the character, extent and significance of heritage assets likely to be effected by development and provide information to determine appropriate mitigation strategies. We would suggest that this is contrary to 2011 Environmental Impact Assessment Regulations. Schedule 4 lists for inclusion: A description of the likely significant effects of the development on the environmental, which should cover the direct effects and any indirect, secondary, cumulative, short, medium and long-term, permanent and temporary, positive and negative effects of the development (Part 4). In the absence of field testing, it is not possible to determine the significance of the heritage assets known to be present, or of the location, extent and significance of assets which have not been responsive to the limited surveys undertaken to date.
4.9 In order to successfully implement preservation in situ, it must be targeted on defined archaeological assets. It would not be appropriate to pick areas of convenience for preservation in situ or to attempt preservation of parts of heritage assets while destroying the remainder. To do so would result in the fragmentation of assets with a resultant loss of understanding and significance. It should be noted that the work undertaken to date indicates that some archaeological assets cover a considerable area (e.g. AP5 and AP6). In the context of the development proposal it is difficult to see how the preservation of these assets in situ could be achieved. Similarly, where preservation by record is to be preferred, we would expect programmes of excavation to address identifiable archaeological assets in a single programme of work. To split the investigation of assets across phases of development would also result in their fragmentation and consequent loss of significance and understanding.
4.10 Officers therefore advise that:
- the application does not adequately define the character, extent and significance of archaeological assets likely to be effected by development; - the application does not make appropriate provision for the management and mitigation of the archaeological resources within the site; - in bringing forward development proposals without an adequate understanding of the archaeological context of the landscape, the applicant is does not consider the potential positive contribution that the historic environment can make to place making and the character of the new settlement.
5.0 NEW COMMUNITIES
5.1 Up to 0.25ha of land has been provided for indoor community facilities which is welcomed. The exact form and function of the proposed facility will be determined at Reserved Matters stage. It is anticipated and supported that the building will provide a base for a variety of different groups and activities, helping to build an inclusive and vibrant community
5.2 It is important that this community facility is suitable for activities for children and young people and their families, especially as Cambourne already has a much higher average of children and young people than the rest of South Cambridgeshire. These community facilities will also need to be suitable for older people and for those with a disability (whether physical, sensory or learning). As noted in the DAS, most community facilities are within a 2km journey which is considered a reasonable walking distance. However, for young children, mums and dads with prams, older people, those in need of support and the disabled this is can be a more difficult distance to walk so it is very important that the community facilities available in Cambourne West are suitable for their needs. This should include provision such as smaller meeting room(s), sports facilities suitable for disabled use (spring floor), disabled toilets, hearing loops etc. To assist with this, the Council, in conjunction with South Cambridgeshire District Council, would like to be involved in the design of the community facilities to ensure the needs of the community as a whole and especially those who may be more vulnerable to social isolation, will be met.
5.3 The community facilities are not planned to be developed in the first phase of the development, which is disappointing, as such facilities can be important in helping to create a community. The Council would therefore seek a commitment from the developer that some form of temporary indoor community facility, outside of a school building, will be available from the outset of the development so that there is space for information sharing and signposting to existing services and a space for the community to meet together. This is especially important for young families, who will need information about the local children’s centre (for example) and for older people and the disabled who may be more vulnerable to social isolation.
Healthcare facilities
5.4 Ref – DAS (pg32). Confirmation is sought that the expansion of the existing GP facilities in Cambourne, as suggested in the DAS, will not have a negative effect on the size of the children’s centre provision that is currently located within the same building (Sackville House).
Environment that promotes positive mental health
5.5 Ref – DAS (pg 58, 62). Officers support the commitment to community greens and good pedestrian and cycle routes (for active transport) as these promote positive mental health benefits. It would be beneficial too if there is also a commitment to providing adequate room sizes.
Physical environment that is accessible and easy to navigate
5.6 Ref – DAS (pg 66 - 68, 82). It is important that the physical environment is accessible and easy to navigate for all members of the community, especially any residents, as with all communities, that may suffer with dementia and for older people who may be more likely to get lost if there is nothing distinctive about the environment. The description of ‘street and blocks’ as a “logical, legible grid to the development” may make different parts of the development look similar, leading to disorientation.
5.7 It is supported that “Landmark buildings should be used at key locations to aid navigability and orientation” (Frontages and Local Areas for Play) and “Completed schemes should create identifiable spaces with local character and distinctiveness” (Place Making). Officers would encourage that other landmarks are used too, possibly using landscaping and public art, to creative distinctive features throughout the development.
5.8 It is also encouraged that sensory and mobility needs are considered in the design, such as textured pavements, sensible placing of street furniture so it does not create a barrier, and level pavements wide enough for ease of and wheelchair and or buggy usage.
Affordable Homes
5.9 Ref - DAS(pg 71). Officers are encouraged by the commitment to a range of affordable housing to meet the needs of the community and expect that the development will be policy compliant with 40% affordable housing.
Social integration
5.10 Ref – DAS (Pg100, 108). Officers are encouraged that the developer has recognized the importance of informal social integration and community infrastructure to enhance youth and community initiatives for example and officers would welcome further details on what the plan is for more formal social integration and what support will be made available to the new residents.
5.11 Officers would welcome the opportunity to work with the applicant to seek a commitment for more formal support and community development, especially for those who may be more vulnerable, to ensure all people are fully integrated and welcomed in the new community. This may be achieved through initiatives such as a commitment to provide community development workers and specialist workers for those who are more susceptible to social isolation (those who are at risk of developing mental health problems and older people for example) and for children and young people. This is important to avoid the higher needs that were witnessed in the earlier development of Cambourne.
Building for Life 12
Ref – DAS (pg 112 -113)
“Facilities and services. Does the development provide (or is it close to) community facilities, such as shops, schools, workplaces, parks, play areas, pubs or cafes?”
5.12 To meet this criteria an additional commitment to early provision of indoor community space for signposting/information sharing and groups/activities to take place should be met.
“Creating well defined streets and spaces. Are buildings designed and positioned with landscaping to define and enhance streets and spaces and are buildings designed to turn street corners well?”
“Easy to find your way around. Is the scheme designed to make it easy to find your way around?”
“Streets for all. Are streets designed in a way that encourage low vehicle speeds and allow them to function as social spaces?”
5.13 As set out above, to meet these criteria it is important that the development is designed with distinctive features so people do not get easily confused or lost and provision is made for those with mobility issues to ensure they can easily navigate around the development. The experience of new developments being that there is a need for community building by the new community itself, and making sure a strong and sustainable community is formed that people want to live in. Officers would be keen to work with the developer and SCDC to ensure a combined approach is taken to community building in this new development.
Section 106 Contributions
Type: Health & Wellbeing of Community
Request obligation: Financial contribution to staff costs (short term 2 years)
Details: Community development workers (specialist mental health) x 2. £75,000 per year (total = £150,000)
Type: health and wellbeing
Request obligation: for financial contribution to the kick start funding for groups and activities for people with disabilities and their carers = £9,292 (OP = £2,761 and LDPD = £6531)
Type: Health and Wellbeing of Community
Request obligation: for financial contribution towards 0.7 of an Independent Domestic Abuse Advisor for two years. Revenue funding = £30,420 per years (total = £60,840.78)
Type: Health & Wellbeing of Community
Request obligation: Financial contribution to staff costs (short term for two years)
Details: Locality workers x 2, Children’s Centre worker x0.7
Flexibility should be given allow the role out of positions as need dictates, staff to be hired on two year contracts
Finance: 2 x Locality workers FTE revenue funding = £69,000 per year. (Total = £139,000)
0.7 x children’s centre worker = £15,467.90 per year (Total = £30,935.80)
Contribution calculated using the known salary banding for similar roles, plus on costs. All salaries based on 1 April 2014 pay scale.
Type: Health and wellbeing
Request obligation of financial Contribution towards an additional social care for a period of two years = £113,333
6.0 HIGHWAYS (See Section 8 for combined response)
7.0 EMPLOYMENT AND ECONOMIC IMPACT ASSESSMENT
7.1 The allocation of employment land within Cambourne West is supported, but only if the currently allocated land for office use (or other potentially appropriate employment use such as technology units) on Cambourne Business Park is retained, and not re-allocated for residential. However, the Council is aware that there are potentially proposals for some residential development on the vacant Business Park land, in accordance with policy SS/8 of the draft local plan. Based on the fact that policy SS/8 would require the provision of 8.1ha of employment land within the smaller site for the Cambourne West proposals (1,200 homes) to be policy compliant this figure would appear to be a starting point for negotiations on this larger proposal. 7.2 The location of the proposed 4.4ha of employment use in the north west corner is noted, however, it is suggested that some of the employment provision would be better situated elsewhere within the development, in order to create a more integrated and balanced community and reducing the need for those Cambourne West residents potentially employed locally to travel to work. The proximity of business uses to the proposed local centre and any development of small business units on the Business Park (which could include solicitors, accountants etc.) should also be considered as part of the master planning of the site. Whilst the proposed access from the A1198 and segregation from residential housing may be appropriate for some uses, other units should be more integrated within the development, which would provide a better balance of uses across the site and generate activity throughout the day across the site. The focus on providing accommodation for medium and small occupiers who require a mix of office, storage and production spaces is welcome and helps address a gap in the current range of facilities available in the area. It is disappointing to note however that this area will not be developed until the later phases. Given the slow take-up of land on the Cambourne Business Park it would be helpful if this could be developed earlier to provide some early employment options for residents on the site. Units for rent by companies should certainly be amongst the mix.
7.3 Assuming the job creation estimates for the proposed employment development in West Cambourne are correct, and when added to the existing employment in Camborne and that proposed for the Cambourne Business Park, it suggests that there will be a broad match between the number of jobs (6300) and the number of houses (6600) in Cambourne when the development is fully completed. However, opportunities to further close any gap should be explored and supported.
8.0 TRANSPORT
8.1 The application has been accompanied by a Transport Assessment (TA). A review of the Transport Assessment submitted in support of the application is provided below. Officers are minded to recommend a holding objection until the development is demonstrated as adequately mitigating its impacts.
8.2 The comments set out in this response represent interim comments on the TA and accompanying information. Further comments may be forthcoming following more detailed analysis and consideration of the additional information required. In addition there will of course be a need for significant further discussion with the applicant’s transport consultants throughout the determination period. This will include how this development interacts with, and contributes towards, the emerging proposals for the A428 corridor such as the A428-M11 segregated bus route and Madingley Road bus priority scheme.
8.3 This response is broken down into the Key Transport Assessment headings.
West Cambourne Transport Assessment
8.4 Paragraph 1.4.1 refers to Guidance for Transport Assessment (March 2007), although it should be noted that this document is now archived.
Planning Policy context
8.5 Paragraph 2.6(g) refers vehicular access being provided through an enhanced route through the Business Park, one or more access points from the Caxton Bypass and via Sheepfold Lane. The development access is not being taken through the Business Park and therefore further justification/ clarification should be provided to explain why this is the case.
8.6 Paragraph 2.9.1 refers to the Guidance on Transport Assessment (Department for Transport, 2007b).This document is now archived and replaced by the National Planning Policy Framework. (NPPF)
8.7 Given that West Cambourne has a proposed allocation of approximately 1,200 homes in the SCDC Local Plan currently at examination, there are already clearly defined transport strategy objectives for a site in this area.
8.8 The location of the proposed development is also in close proximity to the proposed site at Bourn Airfield, both of which lie on the A428 corridor. The Transport Strategy for Cambridge and South Cambridgeshire (TSCSC) has a list of comprehensive proposals for improvements for the A428 corridor. It is therefore important that any site coming forward on this corridor, even if it is separate or additional to the Local Plan allocation, pays heed to these strategic transport proposals for this corridor and doesn’t come forward in silo.
8.9 Major strategic priorities include:
Linking the development to the proposals for a segregated HQPT scheme on the corridor Proposals for an additional P&R site on the A428 corridor Improvements to the A428 Improvements to the Caxton Gibbet and Black Cat roundabouts
8.10 It is also important for any site in this area to include strong sustainable links, including:
Sustainable links into and within the site Sustainable links to the rest of Cambourne and surrounding settlements
8.11 It is also important to state that any County Council comments on an assessment, including a safety assessment, coming from the planning application are specific to that assessment and should not be interpreted as overall agreement that the site fits with the strategic objectives of the corridor.
Existing Transport Conditions
Pedestrian/ Cycle facilities
8.12 Paragraph 3.1.3 includes a list of facilities that are within reasonable walking and cycling distance of the development, however the plans demonstrating this are not clear and should be revisited by the applicant. The county require that walking and cycling isochrones are measured on network rather than as the crow-fly. The facilities should be marked on the appropriate walking and cycling plans, and an audit of provision on these routes to understand any shortcomings that might limit use of these modes by future occupants of the site. Importantly, the propensity for cycling in Cambridgeshire is significantly greater than typically assumed national averages. The 5km threshold distance set out in paragraph 3.1.2 is not therefore accepted by the County Council in a Cambridgeshire context.
Public Transport Facilities
8.13 Figure 3.2 the public transport route plan is not very clear and should be revisited.
8.14 Paragraph 3.2.3 should consider whether the X5 Oxford to Cambridge service plays a role in this corridor.
8.15 Paragraph 3.2.4 should set out what facilities are provided at the identified bus stops including provision of shelters, information, RTPI and so on.
8.16 Paragraph 3.2.6 refers to the closest rail stations to the site and that they are reachable by bus, however it should be made clear which service carries out this journey and what level of service is provided. This will give a better understanding of whether these modes provide an attractive journey choice.
8.17 It is recommended that the applicant refers to the Census 2011 to identify current travel patterns of residents and proportion travelling by the above modes currently.
Highway Network
8.18 Further comments on the highway network and its treatment in this assessment are provided in later sections of the document.
8.19 The Broad Street/ High Street Junction is to be redesigned and therefore all assessments should include this.
8.20 Paragraph 3.3.2 refers to all routes identified as operating within capacity, although this should be demonstrated with evidence rather than stated.
Road Safety
8.21 The accident data should be for the most recent five year period with the manoeuvre data analysed to identify repeat issues that could be exacerbated by the development. The full accident data obtained should be included as an Appendix. 8.22 The B1040/ A428 is also an accident cluster which should be considered as part of the assessment.
8.23 Paragraph 3.4.7 identifies that most accidents occurring at the accident cluster sites are slow moving shunt type accidents and that no common features were identified although without the full accident output it is not possible to confirm this is the case.
Baseline Traffic Volumes
8.24 The Baseline Traffic Survey data has not been provided as part of the application and therefore this information is required to support the baseline survey information presented.
Proposed Development
8.25 Figure 4.2 is not clear and therefore a printed version of the plan should be provided at a suitable scale to ensure it is readable. The current masterplan should be overlaid with the Figure 4.2 drawing to ensure the proposed facilities are clearly set out in the context of the proposed development.
Access
8.26 The Highway Authority are unable to comment on the application in full until the applicant has addressed all the matters raised in the Stage One Safety Audit carried out by Cambridgeshire County Council’s Road Safety Audit Team dated 29th October 2014 have been addressed to the satisfaction of the Highway Authority.
8.27 The Access drawings numbered Figure 9.6 and 85-78i do not correlate to each other. The applicant show only one ‘cycle’ path (this presumably excludes pedestrians) to Lower Cambourne and the proposed pedestrian connections are to un-made leisure public rights of way. The proposed ‘cycle’ path along Sheepfold Lane is intermittent and does not connect to a wider network. Overall the connectivity of the proposed extension to the village of Cambourne is poor and access to the development is car dominated which is contrary to the guidance for new developments contained within Manual for Streets.
8.28 Recently County and District Councillors have raised concerns about the size and nature of new accesses to proposed developments. Whereas it is technically practical to make the proposed designs as presented by the applicant acceptable in engineering terms, the Highway Authority requests that the applicant provide a detailed rationale of why other potential access arrangements were discarded as part of the design process. This will give comfort to all concerned that the most appropriate access for a development of this size and nature has been achieved. 8.29 On drawing number Fig. 9.4 P1 the applicant appears to infer that Sheepfold Lane is a highway. The Highway Authority requests that it is made clear to the applicant that Sheepfold Lane is a private road that until the opening of the Cambourne Village College, it was a no through route that served only commercial units. If the applicant wishes to bring this road forward for adoption by the Highway Authority, the Highway Authority reserves the right to require that it is fully reconstructed to the present requirements of the Highway Authority.
8.30 Dwg No. 855-7K (Phasing Plan), the Highway Authority will not adopt any roads that are being used as haul roads. Whereas the phasing plans seem to be a reasonable way forward for dealing with this issue, the Highway Authority requests that it is drawn to the applicant’s attention that many roads within the development are likely to remain their responsibility for considerable periods of time.
Parking
8.31 The County Council accept the use of the Proposed Submission Local Plan provided this is acceptable to the Local Planning Authority.
Pedestrian, Cycle and Equestrian Proposals
8.32 Paragraphs 4.3.1 and 4.3.2 set out proposed access points and potential routes. This will require detailed further review but currently no information is given on the proposed provision to accompany the development and further work is required to address this.
8.33 Proposals set out in 4.3.5 will require significant further consideration, including interaction with emerging City Deal proposals and handling potential contributions to wider network enhancements.
8.34 Paragraph 4.3.7 proposes settlements to which enhanced provision could be made. The applicant should indicate what improvements would be required. Further discussion will also be needed with the County Council’s PROW team as, whatever improvements are ultimately identified, either delivered by the applicant or through contribution to be agreed with CCC in due course.
Rights Of Way
8.35 The County Council also welcome the intention to create emphasis on the historical features of the existing landscape to engender a sense of embedded identity. This approach works particularly well for green infrastructure and was successfully achieved with the earlier development, for example with the retention of the well-used ancient Crowdene Bridleway through Lower Cambourne. 8.36 The County Council would emphasise the importance of ensuring that good soft-user infrastructure is in place before residents and community facilities. Experience from Upper Cambourne where the school was created before infrastructure was in place showed that people quickly fell into poor habits driving children to school rather than walking or cycling.
A. Proposed new rights of way
1) A footpath link from Lower Cambourne to the spine road and main site access which crosses Cambourne Bridleway 1 2) A Bridleway from the A1198 around the perimeter of the site to link up with Bridleway 2 Cambourne 3) A footpath link from this new bridleway on the north west of the development to the same bridleway on the north east passing the proposed athletics track. 4) A network of cycleways within the development
For all these routes The County Council require clarification as to the details, including width, classification, surface and any path furniture. All new routes should be built to the same standard as the previous Cambourne development using the Cambourne Highway Design guide specification for Footways, Cycleways and Bridleways. They should be clearly identified on the MasterPlan.
The County Council also require clarification as to whether these routes are to be dedicated as Public Rights of Way maintained by the Highways Authority? If they are we would expect the developer to work with us to ensure that they are suitable and meet CCC standards.
8.37 With regard to the new routes described above:
Route 2 - appears to terminate onto the A1198 to the west of the roundabout. Can the developer clarify the detail of what is intended in this location? The County Council would like to see a new 800 metre bridleway created which would continue south alongside Ermine Street to connect BR2 Caxton as shown on the accompanying plan.
Route 3 – Is there sufficient access to this route where it runs in between the sports pavilion and the athletics track? Depending on the exact location of the pavilion the applicant might consider routing the footpath behind the pavilion to reduce risk of future conflict between user of the path and the athletics track.
B. Footpath 17 Caxton 8.38 The southern end of this route is compromised by two new proposed water bodies and will require a Public Path Order to divert it onto the alignment of route 3 above. Please contact Cathy Collins (Asset Information) [email protected] for further guidance.
General principles
8.39 With regard to rights of way which cross the development site we wish to draw your attention to the following principles:
Public rights of way are highways that must remain open and unobstructed at all times, including during site construction. Building materials must not be stored on the public rights of way and contractors’ vehicles must not be parked on them (it is an offence under s 137 of the Highways Act 1980 to obstruct a public right of way). A Code of Construction methodology must be agreed with the County Council’s Rights of Way team for any rights of way affected. A methodology was successfully implemented for the development of Greater and Upper Cambourne. Please see the attached document summarising the methodology and the Cambourne Design Guide for reference. No alteration to the surface of rights of way is permitted without our consent (it is an offence to damage the surface of a highway under s1 of the Criminal Damage Act 1971). Landowners are reminded that it is their responsibility to maintain hedges and fences adjacent to public rights of way, and that any transfer of land should account for any such boundaries (s154 Highways Act 1980). The granting of planning permission does not entitle a developer to obstruct a public right of way (Circular 1/09 para 7.1). Legal orders to realign or create public rights of way take time and therefore need to be carefully programmed in to ensure that development can take place as planned. We would request that the developer sets up regular communication with Asset Information to ensure the optimum outcome for this element of the development. The local communities should be kept informed as to proposed changes to the network, including temporary closure, as objections can significantly delay progress.
C. Request for improvements to the Rights of Way network
8.40 The improvements listed below would allow the communities of Caxton and Cambourne to have better direct links which would especially benefit young people going to school and enable access to the wider countryside via the local rights of way network. These improvements when connected to the developers proposed on site would create an opportunity for a greater circular route out and back to Cambourne for those wishing to take a longer recreational route beyond Caxton, particularly when new sports facilities are being provided on the new development. These improvements would significantly add to the health and wellbeing of both communities and users from further afield in accordance with the policies noted above.
1) A new 800 metre bridleway created from the junction of the proposed bridleway and the roundabout on the A1198 (Route 2) which would continue south alongside Ermine Street to connect BR2 Caxton. This bridleway would enable recreational users from Cambourne to access to the wider countryside via the public rights of way network to the west of Caxton and beyond. Cost = £135,000 for construction works. Administrative fee for the legal order approximately £4,000 2) An improvement to the surface of Bridleway 5 Caxton/Bridleway 4 Cambourne which is the main route between Caxton and Cambourne. This route is used by many young people to go to schools in Cambourne. Total distance approx. 1580 metres. Cost = £250,000. 3) An improvement to the surface of 170 metres of Footpath 7 Caxton. This route is a popular route for parents and young people to use for catching the school bus. Cost = £15,000.
8.41 These costs are all estimates based on previous improvement schemes.
8.42 Further discussion on feasibility of delivering these will be needed with the applicant.
Public Transport Proposals
8.43 Further details on the proposed services will be required with CCC’s passenger transport team on the acceptability or otherwise of the proposals set out in paragraph 4.4.3.
8.44 In due course more detailed proposals for how the bus services, if agreed, can be phased in and assessments made by the applicant of patronage levels. This will allow levels of potential pump-priming subsidy to be identified which CCC would secure through s106.
8.45 Paragraph 4.4.8 –The proposed provision of a bus lane will require significant further consideration by the County Council, particularly in the light of Council’s emerging thinking on wider transport provision in this corridor to accommodate growth from developments including at land west of Cambourne for which CCC will look to secure a proportionate contribution. This includes the proposed A428-M11 segregated bus route and Madingley Road bus priority schemes. Notwithstanding this, the applicant has not provided adequate evidence to demonstrate the claimed betterment in para 4.4.9, and further reassurance is required that the proposal set out would actually be deliverable in either public highway, in land under the control of the applicant, and without any special permissions being required.
8.46 Paragraph 4.4.11 – It should be demonstrated that all dwellings will be within 400m walk of a bus stop. All stops will require bus shelters and installation of RTPI and it is not acceptable to limit provision to just four stops should more be required
Travel Plan
8.47 Travel Plan comments are provided below. In any event the travel plan would need to be agreed via planning condition or obligation with the County Council expecting stretching targets to minimise single occupancy car use being achieved.
Construction Traffic
8.48 Issues concerning haul roads are included in the access section of this response.
8.49 A construction management plan will need to be agreed prior to commencement on site.
Accessibility Assessment
8.50 Figure 5.1 walk isochrones should be on network rather than as the crow-fly. The walking speed assumed should be provided. The facilities identified in Table 5.1 should be included on Figure 5.1. Cycle isochrones are also required.
8.51 The most recent National Travel Survey journey time to each facility should be included in Table 5.1 as a comparison, currently 2009 survey is referred to whilst it is understood that 2012 data is available for journey times to each facility. The Indicator column should be separated by mode e.g. walk, cycle and public transport journey times rather than combined. The walking and cycling speed should be clearly defined and where possible actual distances provided. The journey times should be measured on carriageway rather as the crow-fly.
8.52 The accessibility to facilities by each mode is dependent on the suitability of the infrastructure available to reach these destinations, therefore journey times to facilities should only be identified where it is possible to undertaken a journey by each mode.
8.53 Figure 5.2 does not appear to have been submitted as part of the current Transport Assessment. Forecast Traffic Demand
Derivation of Base Traffic Flows
8.54 The growth factors identified in Table 6.1 should be compared to TEMPRO to demonstrate the appropriateness of the factors applied.
8.55 Paragraph 6.2.4 identifies that the CSRM includes 1,200 residential units that it assumes will be provided at the Proposed Development site at West Cambourne. It is not acceptable for part of the West Cambourne development to be included in the 2031 base as an allocated development. This will result in part of the development impact being accounted for as part of the background growth and committed development, rather than demonstrate the full development impact.
8.56 Paragraph 6.2.7 refers to the use of the 4,250 traffic flows to identify internal Cambourne junction growth factors, although it is not clear where the traffic flows have been sourced from and therefore further information is required. Similarly the 2013 traffic surveys have not been provided and therefore it is not clear where the flow figure in Table 6.2 has been sourced.
8.57 It is not made clear whether growth has been applied to internal network to account for the remaining non-residential development coming forward in Cambourne and therefore further explanation and reassurances are required.
8.58 Paragraph 6.2.8 refers to the junction growth factors associated with the remaining junctions being broadly in line with traffic growth figures derived for the area previously and are considered a fair basis for the assessment, although this should be demonstrated.
Development Trip Overview
8.59 The County Council require trip generation by mode for both peaks and daily trips to be provided. This should also quantify the relative distribution and those travelling within/ beyond Cambourne.
Residential Trip Generation
8.60 The Person Trip rates identified in Table 6.2 match with those presented in Table 7.1 of the Cambourne 950 Transport Assessment, which were calculated using surveys of Cambourne dwellings. The Cambourne surveys were undertaken in 2007 although details such as proportion of residential dwellings occupied at the time have not been provided.
8.61 The mode choice has been informed by the Cambourne Household Survey (2007), however this should be compared to the 2011 Census data. 8.62 The Residential trip rates presented in Table 6.3 are lower than those presented in Table 7.2 of the Cambourne 950 Transport Assessment. Furthermore, CCC have been unable to verify the derivation of the traffic generation figures shown in Table 6.3 and how these relate to data shown in Table 6.2.
8.63 Paragraph 6.4.2 referred to a calibration of the Cambourne Household Survey data against TRICs data, although it is not clear where this analysis has been carried out and whether the TRICs data has been provided, and therefore further information is required.
Commercial Trip Generation
8.64 The TRICs database outputs should be provided in order that the County Council can check the site selections.
8.65 It is not made clear whether a light industrial trip rate is the most appropriate to represent the non-residential land uses included in the application, and therefore further consideration should be given to this. The proposed commercial premises could potentially be occupied at a much greater density than implied through use of light industry assumptions. This could give rise to greater levels of trip generation. Further assessment work will be required to provide reassurance that any conclusions ultimately drawn on transport impact are robust to this potential outcome.
Development Traffic Distribution
8.66 The County require that the applicant compare the distribution applied to that contained in the Census 2011 for both residential and employment trip ends.
8.67 Paragraph 6.6.5 refers to route choice being determined by the shortest journey time. The routing applied for each destination should be identified and evidenced as part of the Transport Assessment.
8.68 The Commercial trip distribution and route choice has been identified using observed turning movements, although these should be calibrated using Census 2011 data and route choice assessment.
Peak hour Forecast Scenarios
8.69 The assessment scenarios are not acceptable to the County Council. The 2031 base year should contain none of the current proposals (allocated or unallocated). The 2031 base plus development should include all 2,350 dwellings. Without this it is not possible to understand the incremental impact of the development.
Traffic Impact Assessment 8.70 The County Council are unable to comment on this section of the Transport Assessment at this stage as we do not accept assessment scenarios. This section will need to be rerun once the above comments have been revised and agreed. We provide the following comments in the interim.
8.71 Paragraph 7.1.1 needs to explain how these time periods match with those proposed in the trip generation section which are different.
8.72 The County require that junction geometry measurements be provided to check those presented in each of the junction modelling scenarios. In addition, all junction models should be run with existing traffic flows to demonstrate that the models are able to replicate observed queuing and delays. Without these two pieces of information the County Council is unable to confirm whether the junction models in their current format are acceptable. When this has been provided it is recommended that the junction modelling is resubmitted showing three scenarios:
(i) observed
(ii) future baseline with no development at Cambourne West
(iii) future baseline plus development at Cambourne West
8.73 Paragraph 7.2.15 implies that a degree of saturation of less than 0.90 indicates that a junction is operating within capacity. This is accepted for signalised junctions but not for uncontrolled junctions where a value of 0.85 must be used.
8.74 Paragraph 7.2.17 refers to the use of ODTAB to input flows into Arcady, the County are unable to agree this approach without the 2013 traffic surveys being provided to demonstrate the assumed profile is appropriate.
8.75 The School Lane/ Broad Street junction modelling should take account of the latest junction design. It is not discussed why this junction is not appropriate for PICADY modelling and therefore further justification is required to clarify why LinSig was used to model a priority junction.
8.76 The Cambourne Interchange Southern Roundabout (p58) will also need to be modelled in its existing configuration with the ‘no Cambourne West’ flows so that baseline conditions in the absence of the development can be understood.
8.77 For the proposed junction arrangements a link diagram should be provided. Notwithstanding the wider issues identified above it is noted that some arms are operating in excess of capacity.
Travel Plan 8.78 The wider Cambourne settlement is identified as already benefitting from an existing Travel Plan for the existing 950 Cambourne development. The proposed development Travel Plan is to supersede the existing strategy to provide an enhanced overall Travel Plan Strategy. The objectives of the overall Travel Plan Strategy presented in this document need to be clearer and how the proposed development Travel Plan relates to the 950 Cambourne Travel Plan and the remaining (3,300 dwelling) Cambourne settlement.
8.79 Further details should be provided to identify the success of the Cambourne 950 Travel Plan so far which can be used to inform the proposed development Travel Plan.
8.80 This travel plan sets overall outcomes, targets and indicators for the development site.
8.81 Paragraph 1.3.1 incorrectly quotes the permitted number of dwellings in the Cambourne settlement.
8.82 Paragraph 1.4.3 appears to be incomplete.
8.83 Paragraph 1.4.5 does not make it clear how the Travel Plan will integrate with existing business users or monitor the existing 4,250 dwellings and schools within the settlement and therefore further information is required.
8.84 The draft document does not set the parameters for the requirement for individual sites (or uses / elements) within the overall development to prepare and implement their own subsidiary travel plans. The timeframe for completion of individual travel plans should be detailed.
8.85 The Travel Plan needs to include how potential and existing occupiers will be advised of the travel plan requirements (there is little or no evidence of this to date).
8.86 Paragraph 4.2.1 appears to be incomplete.
8.87 The Travel Plan should be updated in light of the comments provided on the relevant sections of the Transport Assessment detailed earlier in this response.
8.88 The proposed measures were implemented as part of the Cambourne 950 development although details are not provided as to the successes and failures, and therefore further information should be provided.
8.89 The Travel Plan Coordinator should be employed for a minimum of 5 years post full occupation to align with the required monitoring period. It is unclear who the role of Travel Plan Coordinator will be passed to after this period, and therefore further consideration should be given to this. 8.90 There is a lack of management overview and responsibility in the Travel Plan. The Travel Plan should make reference to the Developer responsibilities which should include: chairing the Travel Plan Steering Group, managing the travel plan co-ordinator and being responsible for monitoring and review. It should be noted that the 950 travel plan by RPS states “6.4 A representative of the developer (initially the Project Director) will act as Travel Plan Coordinator (TPC). The TPC will be supported by consultants, as and when required, and will work closely with Cambourne Parish Council (CPC) and relevant resident bodies.”
8.91 Welcome Packs should include one month taster tickets for local bus services and discounts at local bikes shops to purchase cycle goods and accessories.
8.92 Cambourne 950 travel survey information can be used to identify interim targets, although the baseline survey should be carried out on the new development in order to understand current travel patterns on which to measure future progress. It is not clear whether monitoring of the development will coordinate with the rest of the Cambourne settlement.
8.93 The timing of the baseline and subsequent surveys will need to be agreed with the County Council. Monitoring should continue for 5 year post full occupation.
8.94 The Targets presented in Table 7.1 are stretching but realistic when compared to the 2011 travel from Cambourne census and the TfC travel to work surveys for Cambourne between 2009 and 2014. The travel plan does not explain why the interim targets are higher and more challenging than the longer term combined modal split and therefore further information is required. The Travel Plan targets should be compared to the achievements of the Cambourne 950 Travel Plan to date to assess their appropriateness.
Conclusions
8.95 We welcome the Transport Assessment and Residential Travel Plan provided as part of this application. However, as outlined above, significant additional information and clarification is required before the County Council can give a view on the full impact of the development including a reassessment based on the actual development proposals in the planning application. Without this the incremental impact of the development cannot be understood and any required mitigation measures identified. Further consideration will also be required on the relationship this development proposal has with wider County Council proposals to accommodate developments, including that land west of Cambourne. These include the A428 – M11segrated bus route and Madingley Road bus priority schemes for which proportionate contributions will be sought from this development. Therefore we would recommend a holding objection on this development until this additional information has been provided and fully reviewed by the County Council. As noted above, these comments cannot be exhaustive at this stage as the additional information will invariably identify further issues that will require resolution
28 January 2015
Appendix 1: EDUCATION
1.0 Introduction
1.1 The application is an outline application with all matters reserved other than access and therefore the layout masterplan and the planning, design and access statement are only indicative at this stage. The application does however clearly set out the proposed locations and design parameters for the proposed secondary school and the two proposed primary schools. It is therefore important to assess key parameter issues at this stage. A response to the key areas in the application from a design, location and planning perspective is set out in this response.
1.2 Provision has been made for 2 primary schools (both 2FE) and one secondary school (4FE). A schools campus has been proposed following the development of the secondary school and one of the primary schools in close proximity of the existing Cambourne Secondary School College.
1.3 The second primary school is proposed to be centrally located within the new development.
2.0 Design and Access Statement
2.1 Size and location of Schools
2.1.1 The proposed school site sizes are as follows: • Primary school 1: 2.2 ha in size • Primary school 2: 2.7 ha in size • Secondary school: 6.4 ha in size
No objection is raised in principle to the size of the proposed schools, although it has not been made clear within the submission whether the school sites will incorporate Early Year and Childcare facilities.
2.1.2 The clustering of schools within the school campus, (new and existing secondary schools, Hardwick’s Cambourne Campus and Primary School 1), represents good urban design. However, significant care will need to be taken in designing the access and connectivity to and from this area. In total, these four education establishments will ultimately provide places for at least 2,700 pupils. Significant consideration will need to be given to movement and access arrangements to ensure that the impact of this number of pupils, and additional staff travel, do not have a significant impact on the surrounding transport infrastructure. This is especially true in relation to the impact at peak school travel times. It is critical that this is considered from the outset of planning, and that the outline planning application does not create a transport network and infrastructure which prevents successful delivery of education infrastructure.
2.1.3 It is recommended that at design code / detailed design stage that the Cluster of Schools are designed with separate staff and visitor access points. In particular the drop off area for pupils should be on the public highway and located away from the staff entrances to minimise congestion.
2.1.4 CCC Education would like to be consulted on the arrangements for the highway network adjacent to the cluster of schools from early stages, to ensure that the arrangements will work from an educational perspective.
2.2 Primary Schools
2.2.1 The County Council’s adopted policy is for all new primary schools to be developed with accommodation and facilities to facilitate the delivery of early years provision. This approach was established in policy by the Council’s Cabinet in September 2007, and is required to ensure that the Council is able to fulfil its statutory duties as set out in the Childcare Act 2005. The requirement for site area is for two form entry schools to be located on 2.3 hectare sites, which should meet specifications established by Cabinet in January 2014.
2.2.2 To meet this requirement, the County Council would require the site of primary school 1 to be increased from 2.2 ha to 2.3 ha.
2.2.3 It is recognised that the proposed site area for primary school 2 is 0.4ha larger than the Council’s minimum requirement. However, should the developer, wish to make this size site available at no additional cost this would be welcomed by the Council. This would provide greater flexibility and address concerns which may exist locally given the history of Cambourne, and the pressures arising from the documents high birthrate.
2.2.4 Both primary schools are situated relatively centrally within the development. These central locations to ensure that the primary schools are within a 10 minute walk of all parts of . This is a considerable benefit when encouraging the use of sustainable methods of transport.
2.3 Secondary School
2.3.1 The site area proposed for the secondary school site is in line with the requirements set out in the Department for Education’s (DfE) Building Bulletin guidance. In this regard, the Council is content with the scale of the site proposed in the outline masterplan.
2.3.2 The principle of the school being located adjacent to the existing Cambourne Village College to form an education hub at the centre of the development is supported. This will enable the new provision to become an expansion of Cambourne Village College, with good relationship to the existing settlement of Cambourne to the east and the proposed expansion to the west, supporting community cohesion and the integration of the new and existing communities, and is supported.
2.3.3 In addition, the location of the secondary schools will ensure that all properties would be within a 15 minute walk of secondary education provision. This is considered suitable and favourable for the encouragement of sustainable transport use.
2.3.4 The Council is aware that the site currently proposed for the secondary school does raise a number of other challenges in relation to the wider connectivity and relationships between existing and proposed communities. As is outlined above, the current arrangement is in principle, supported by the Council from an education perspective. The Council would request that officers from the 0- 19 Place Planning and Organisation service are involved in any subsequent masterplanning discussions relating to the relocation or retention of the currently proposed education provision.
2.3.5 The co-joining of sites will also enable the sharing of facilities and services however it must be ensured that all facilities that are provided have a suitable capacity for both of the schools. This approach also promotes a number of potential opportunities through which the Council, working alongside the Comberton Educational Trust, can secure a sustainable approach for delivering secondary education in Cambourne. Whilst it is understood that the application shows a new secondary school on the southern edge of the additional site, the Council is aware that this may not be the most appropriate location for the additional accommodation to be sited. The Council considers that the secondary school site should be considered as a single site, rather than as a second school. This would ensure that there is sufficient flexibility for the delivery of secondary school provision to be planned and delivered effectively. This should also include the potential for removing / relocating existing planting across the larger site so that this does not become a constraint preventing the delivery of suitable education provision.
2.4 Connectivity of the Schools
2.4.1 The proposed secondary school is located adjacent to a cycleway on its west and south boundaries. Confirmation should be sought from the applicants that this will be a joint cycleway and pedestrian route. This approach is supported and will encourage sustainable modes of transport to the school both by foot and cycle from both the existing settlement of Cambourne and the proposed new settlement. This represents good urban design.
2.4.2 The main route to the Secondary school is served by a loop road, which appears to be designed for the drop off of school children. This approach is supported in principle; however careful design will be required at detailed application stage to ensure adequate space is available to avoid congestion. In addition a separate access will need to be provided to the secondary school away from the drop off area. It is considered that this is a matter that can be fully considered at detailed design stage.
2.4.3 It is worth highlighting that, in designing the access and parking at Cambourne Village College, the County Council responded to the request / desire of the landowner and their representatives to develop a design which would allow main access to come into the middle of the site through the housing block shown adjacent to the school site in the planning application. The fact that the emerging masterplan has been developed in a totally different manner is rather disappointing, as this may undermine the long-term vision and approach adopted during the design of the current secondary and primary school entrance and parking.
2.4.4 The proposed primary school in the western part of the development is adjacent to a ‘loop road’ on its south- west and north- west boundaries, albeit separated by a cycle route and attenuation area. The entrance to the school is proposed to be located in the eastern part of the site, adjacent to the existing public right of way and in close proximity to the spine road. The preference of CCC would be to have a spill out area in front of the school away from the spine road, and although the current relationship is not ideal in this regard, there does appear space for a spill out area. It is considered that this is matter than can be considered further at detailed design stage, especially given that it is stipulated elsewhere in the D&A that the schools will be free from traffic at their entrances.
2.4.5 It has been proposed that the main outdoor sport area and a large neighbourhood play area close to the northern primary school and western primary school respectively. This proposed location, and the type of facilities which are proposed, specifically the full sized athletics track are welcomed by the Council. These facilities will provide unique access to this type of facility within South Cambridgeshire. The proximity of these additional facilities will potentially enable the school to offer a greater breadth of curriculum.
2.4.6 This main outdoor sports area offers the potential for a range of uses that will not be subject to noise and over-looking issues as residential properties may be. This is positive in ensuring that there can be a full range of activities hosted at these facilities.
2.4.7 It is important to highlight that SCDC policy prevents the use of school sports pitches being counted towards the community sports provision (Stuart, can you insert the appropriate policy reference). Whilst the proximity of the community sports provision therefore offers a range of benefits, which will help to ensure that the schools are integrated with other community services and facilities, this does not provide an opportunity to reduce the quantum of land available for either type of provision.
2.4.8 All schools appear to be well accessed in terms of cycle and walking routes. This approach is supported.
2.5 LEAPs and NEAPs
2.5.1 It is noted and supported that LEAPs and NEAPs are situated on the green spaces allocated close by to the schools. This is a logical arrangement to ensure the play areas are accessible and well-used by the younger population and is good urban design.
2.6 Bus Routes
2.6.1 The spine road will enable bus routes to run directly to the schools, which is important especially for the Secondary Schools and is an approach that is supported.
2.6.2 It is supported that the frontage of the schools will be designated for buses and non-motorised traffic only. This will help ensure the safety of pupils and staff when arriving and leaving the school by minimising traffic in the immediate vicinity of the school, and discourage the use of unsustainable private vehicles for school journeys.
2.6.3 However, as noted in paragraph 2.1.2 above. A significant amount of school related traffic, of all modes of travel, including walking, is likely to be concentrated around the proposed school campus area. This could present a number of challenges, for all users and residents. This could have a negative impact on the flow of traffic in the area around the school. The roads in this area, especially the spine road, will need to be designed carefully to ensure that they are able to cope with the volume of traffic, and do not create challenges to the safety of users, especially younger school-aged children.
2.7 Heights of School Buildings
2.7.1 It has been proposed that school building heights will not exceed 12.0m. It is considered that this is overly restrictive, especially having regard to the proposed height of the Secondary School, which is likely to be higher than 12 metres in height. It is recommended that the Design and Access Statement is amended to give a height parameter of up to 15 metres for all school buildings. It is supported that there is no minimum building height, to give flexibility at detailed design stage.
2.7.2 Having maximum heights of 15m for secondary school has become the Council’s standard approach in planning for the delivery of major housing developments across the county. Having this greater flexibility around the height of school buildings allows for greater flexibility in developing the adjacencies of different facilities within the school. The experience of providers who have recently designed Trumpington Community College and North Cambridge Academy has illustrated that having this additional flexibility can generate benefits in-terms of school design.
2.8 Levels
2.8.1 A contour map featured in the Design and Access Statement shows the site for the western most primary school to be of a noticeable gradient. The school playing fields will require a minimum gradient of approximately 1:70, which will be a requirement of the Section106 agreement. Confirmation from the applicants should be sought at planning application stage to ensure that the school sites can be delivered as flat sites, without significant impact in other areas of the masterplan.
3. Planning Statement
3.1 It is supported that the location of the development in relation to the existing Cambourne College allows for the central hub around this school and the proposed future schools to develop quickly and provide facilities for the initial phases of Cambourne West. The eastern-most parts of the development are to be built out first, ensuring reasonable access to existing school provision until the critical level of demand is reached for the new schools to be developed. The phasing and delivery of the schools will be considered further as part of the Section106 agreement.
4. Sustainability Assessment
4.1 A 10% renewable energy level has been set for the development as a whole. It has been estimated that up to 37% of the estimated total regulated energy consumption from educational buildings can be met by photovoltaic. It has also been considered that solar hot water and air source heat pumps could provide a low/medium contribution to the overall 10% renewables requirement. The uses of such energy resources will be considered in the more detailed design stages however this will be subject to an assessment of viability for the development of the three new schools.
4.2 Whilst some flexibility has been included in the sustainability statement, it is not appropriate to require 37% of energy requirements from photovoltaic cells, along with air source and solar hot water. This level of provision would add significantly to the capital cost of the school and is not appropriate accounting for adopted planning policy and that the development requirement across the site is only 10%. If the applicants were proposing this level of renewable energy for the schools, a considerable increase in contribution to the Section106 would be required.
5. Environmental Statement
5.1 Space for 2.54ha of community allotments has been proposed for space adjacent to the proposed secondary school. This is a land use considered to have a low impact on the school however security at the boundary between the two sites will need to be considered at detailed application stage.
5.2 Transport
5.2.1 It is supported that there would be no access for the construction traffic to the site via School Lane. This is to ensure that the sensitive schools and colleges will be avoided and will not be impacted by the potential noise, safety and air quality impacts that construction vehicles may have.
5.2.2 Table 9.20 sets out that provision of a school crossing assistance should be provided to mitigate the impact of the development on School Lane. Whilst this is recognised as being a positive approach. As such, it is supported that school crossing assistance during school starting and ending times will be provided and that an on-going commitment for a school crossing patrol warden to operate during the busiest pedestrian times will be enforced. However, it is unclear how this will be funded, and what expectations exist around how this mitigation will be secured. There will need to be consideration to if this can be secured, especially in the short-term, through a S106 contribution from the development.
5.3 Noise
5.3.1 Noise to the schools has not been assessed in detail as part of the noise chapter. However, the schools appear to have been located in appropriate locations away from the A428, which is the main noise generating source near the site. The eastern of the two primary schools is located in close proximity to the main spine road, which does have the potential to generate some noise to the school. However, this is only in the north- west corner of the site, with separation provided from the playing fields to the west of the school. It is therefore considered that this is a matter than is likely to be able to be addressed at detailed design stage and no objection is raised to the application in terms of noise.
5.4 Lighting
5.4.1 A pedestrian right of way along the boundary of the proposed development and adjacent to the proposed secondary school has been recognised as being likely to be used for commuting bats. Although this imposes light restrictions, it should be ensured that the footpath is adequately lit to provide a safe route for pedestrian accessing the school. The need for lighting of this route should be a condition on any grant of planning permission.
6. Conclusion
6.1 The application is generally supported when considering the location and constraints of the school sites within the development. The location of the schools has clearly been subject to detailed urban design considerations. The schools appear to be well related to the proposed development parcels. The provision for good cycle links and pedestrian connectivity to the schools and the provision for NEAP’s are supported. The Design and Access Statement also stipulates that the front of schools will be pedestrian areas, free from vehicular traffic, which is welcomed and will require further consideration at detailed design stage.
6.2 There are some matters of detail that will need to be addressed as part of the outline planning application process of by way of planning condition/Section106 agreement:
The contours at the school site in the western part of the development to be at a noticeable gradient. It will be a requirement of the Section106 agreement for this site to be flat and confirmation should be sought from the applicants that this can be achieved prior to the determination of the application. The maximum heights of the school buildings are set as 12 metres. To give the flexibility required at detailed design stage, it is considered that this should be increased to 15 metres. The renewable energy statement contains a series of potential recommendations for the schools. Unless the applicants are willing to fund the provision of increased renewable energy within the school sites as part of the Section106 agreement, it is unreasonable for the school buildings to provide a higher level of renewable energy than that required by policy. Early Years and Childcare Facilities will be required at the primary school sites
6.3 Subject to the above matters of detail being addressed/clarified there is no objection to the planning application.
Appendix B Indicative Section 106 Costs
Summary table of emerging issues and contributions (amounts specified are indicative in some cases and therefore are subject to further discussion and agreement) Service Issues S106 Contributions Education Flat and free serviced 2 x 2FE Primary school sites; School site Schools (£8.5M sizes; Maximum school (4Q2014) each) and 1 x heights too low; 4FE Secondary School renewables (Cost TBC). funding/requirement; EY and Childcare Facilities provision. Life Long Learning £42.12 per head = 6345 x 42.12 = £267,250 Waste Disposal Planning Holding objection until £425,350 Authority & Waste Planning s106 contributions Authority secured until RECAP requirements and HRC contribution agreed. Planning conditions required for CEMP and Waste Audit Transport Holding objection until additional information provided and reviewed by County Council New communities Temporary provision of Community community facilities; development workers x impact on Sackville 2 - £150k; kickstart House Children’s centre; funding £10k; 2 x affordable housing Locality workers £140k; levels Children’s Centre worker £15.5k; and social care £113k. Archaeology Holding objection until trenching concerns addressed S106 monitoring £60k (County Policy - Monitoring fees charged at 1% on the initial £2m and 0.5% thereafter, subject to a cap of £60K).
S/2903/14/OL – West Cambourne development of up to 2350 houses - Caxton Parish Council response
Caxton Parish Council recommends refusal on the grounds that: This outline plan greatly exceeds in terms of area and number of dwellings the current proposal of SCDC for West Cambourne in their Local Plan currently before the Inspector.
This represents a cynical attempt by the developer to get this proposal before the Council, and probably to appeal, whilst SCDC is unable to prove a ‘Five Year Housing Supply’ and thus increase pressure on the Inspector to approve ‘West Cambourne’.
The Site This development is in the wrong place as there is little local employment. Opportunities for employment are mainly at Cambridge, St Neots and Huntingdon, all requiring a minimum 8 to 10 mile commute. There is a token attempt at local employment by including a small area of ‘Employment Land’ to the north west of the site. Even this is outward facing and cannot be accessed from within West Cambourne and requires one to exit onto the A1198 and re-enter near the Caxton Gibbet roundabout. The proposal is for a ‘commuter town’ as it is not sustainable with regard to employment.
Infrastructure The local infrastructure is currently woefully inadequate as witnessed by anybody who needs to travel to or from any of the local towns during the rush hour. The proposed solutions to this are: 1) Dualling of the A428 from Bedford to Caxton Gibbet, a Ministry of Transport funded proposal not yet ‘signed and sealed’ and probably dependent upon the outcome of the forthcoming General Election. It is, however, Government policy that the A428 should be used to relieve traffic problems whilst the A14 is being re-routed. 2) A busway/high quality bus priority – West Cambourne to Queen’s Road, Cambridge, with a 1000 Park and Ride on the A428 in the Bourn Airfield/Cambourne area. If and when these proposals are completed the traffic generated by the developments of many thousands of houses already going ahead to the west of Caxton will no doubt join the inevitable queue where buses share the road but have priority. No doubt the ‘local’ Cambourne West residents with their 4000 or 5000 cars will quickly learn the best routes via our villages, turning them into ‘rat-runs’.
Sewage This developer has proved to be less than able to plan adequately for the necessary infrastructure to deal with the pumping and disposal of sewage.
Health Facilities There is already a serious shortage of Doctors and Dentists in Cambourne, which is beginning to impact on surrounding villages. Some are already having to go as far afield as St Neots to get a Doctor’s appointment and the Upper Cambourne development is not yet completed. We have an ageing population which will itself bring further pressures. This problem has not been resolved during the past ten years so what chance is there with another 5000 plus residents.
The Land This site is grade A arable land, a commodity which is in short supply in our country and should not be defiled by development.
Flooding Whilst it is acknowledged that development does not necessarily mean additional flood risk if properly planned and implemented, it must be borne in mind that with global warming the incidence of ‘one in a hundred’ floods becomes ever more frequent – two already this century, which caused substantial flooding in Caxton, Bourn and other villages to the east. Caxton and Bourn are downhill from Cambourne West and are at a higher risk from such events which would be exacerbated by this development! The Town Hall, Market Hill St Ives, Cambs PE27 5AL
01480 396698
www.cprecambs.org.uk
Mr E Durrant Planning and New Communities CPRE Cambridgeshire and Peterborough is our South Cambridgeshire District Council local branch of CPRE, a national charity. We speak up for the English countryside: to South Cambridgeshire Hall protect it from the threats it faces, and to Cambourne Business Park shape its future for the better Cambourne Cambridge CB23 6EA
18 February 2015
Dear Mr Durrant
Application Ref. S/2903/14/OL 2,350 residential units, etc at Land to the West of Cambourne
CPRE wishes to register its objection to this application.
It is recognised that there are advantages of extending Cambourne in preference to breaking into a new site at Bourn Airfield. Whilst CPRE favours development on brownfield sites over greenfield, we are aware that there is an issue of how much of the former Airfield can properly be regarded as brownfield.
Nevertheless, the application for extending Cambourne to the West of the village should be refused as it premature to the consideration of the South Cambridgeshire Local Plant currently at Examination.
A further reason for objecting to the extension of Cambourne is the lack of high quality public transport. Any significant development in this corridor between Cambridge and St Neots should be predicated on the provision of high quality public transport along the A428.
Yours sincerely
Shirley Fieldhouse CPRE Cambridgeshire & Peterborough
President Christopher Vane Percy Chairman Mr Michael Monk Vice-Chairman Sally Jackson
Registered charity number 242809
Croydon Parish Council 10/02/2015
Dear Sirs
Land to the West of Cambourne (excluding Swansley Wood Farm) - S/2903/14/OL
Council would like to object to the massive development to the west of Cambourne on the following grounds:- increased traffic movements with no mention of improvements to the existing local road network. The A428 is already struggling to cope with the current traffic it carries and the A1198 is only single carriageway and not suitable for a huge increase in traffic.
There needs to be a great deal of thought put into the impact of a development of this size on the locality, and the needs of its residents should it be built. Another doctors’ surgery, a dentist, a bank, post office, clothes shops etc. should all be considered.
Council appreciates that more housing is needed and has to go somewhere, but at least consider improving the infrastructure before potentially thousands more people are brought into the area,
Sincerely
Marian Burling Clerk to Croydon PC
Edward Durrant Our ref: AC/2015/122351/01-L01 South Cambridgeshire District Council Your ref: S/2903/14 Development Control South Cambridgeshire Hall (6010) Date: 02 February 2015 Cambourne Business Park Cambourne Cambridge CB3 6EA
Dear Sir
DEVELOPMENT OF UP TO 2,350 RESIDENTIAL UNITS INCLUDING AFFORDABLE HOUSING; RETAIL, USE CLASSES A1-A5 (UP TO 1.04 HA); OFFICES/LIGHT INDUSTRY, USE CLASS B1 (UP TO 5.66HA); COMMUNITY AND LEISURE FACILITIES, USE CLASS D1 AND D2 (UP TO 0.92 HA); TWO PRIMARY SCHOOLS AND ONE SECONDARY SCHOOL (UP TO 11.28 HA), USE CLASS D1; THREE VEHICULAR ACCESS POINTS INCLUDING THE EXTENSION AND MODIFICATION OF SHEEPFOLD LANE, A FOUR ARM ROUNDABOUT PROVIDED ON A1198/CAXTON BYPASS AND AN ACCESS POINT OFF THE A1198, SOUTH OF THE CAXTON GIBBET TO SERVE THE PROPOSED EMPLOYMENT USES; A NETWORK OF SEGREGATED PEDESTRIAN AND CYCLE ROUTES; SUSTAINABLE DRAINAGE SYSTEM AND OTHER INFRASTRUCTURE; TOGETHER WITH ASSOCIATED EARTH WORKS, PARKING, OPEN SPACE, INCLUDING EQUIPPED PLAY, PLAYING FIELDS AND LANDSCAPING. LAND TO THE WEST OF CAMBOURNE (EXCLUDING SWANSLEY WOOD FARM).
Thank you for your consultation received 14 January 2015.
An electronic copy of the decision notice would be appreciated.
Environment Agency position – Development & Floodrisk. In the absence of an acceptable Flood Risk Assessment (FRA), we OBJECT, in detail, to the grant of planning permission and recommend refusal on this basis for the following reasons:
Reasons. The FRA submitted with this application fails to demonstrate that there will be no increase in flood risk elsewhere as a result of the proposed development. As such, the FRA does not comply with the requirements set out in paragraph 102 of the National Planning Policy Framework. In particular, the submitted FRA fails to:
Demonstrate that the peak discharge rate for all events up to and including the 1 in 100 chance in any year critical storm event, including an appropriate allowance for climate change, will not exceed that of the existing site.
Demonstrate that the storage volume required to attenuate surface water run-off from the critical 1 in 100 chance in any year storm event, with an appropriate allowance for climate change, can be provided on site.
Overcoming our Objection. Our Objection can be overcome by submitting an FRA which addresses the deficiencies detailed below and demonstrates that the development will not increase flood risk elsewhere and, where possible, reduces flood risk overall.
The FRA indicates that discharge rates will be restricted to the 1 in 2 year Greenfield run-off rate for each of the three catchment areas identified. However, the calculated ‘Greenfield’ runoff rate in the East part of the site includes an allowance for the existing runoff from the impermeable area in this part of the site. This is unacceptable for the following reasons: - Runoff from the existing Brownfield area of the site should not be included in any calculations of Greenfield runoff rates. This Brownfield runoff can only be included in calculations of the existing runoff rates from the part of the site that positively drains this area. - No evidence has been provided to demonstrate that the existing impermeable area generates the runoff rates calculated in the FRA (i.e. 33.42 l/s/ha in the 1 in 1 year event) and that this impermeable area is positively drained in the East part of the site. We consider that the Modified Rational Method that has been used to calculate the runoff rates from this impermeable area is likely to have overestimated the existing runoff rates. As such, details of where and how this area is currently drained must be provided, as well as further evidence of the existing discharge rates, taking into account any infiltration. - Although some allowance can be made for this existing runoff in the post-development discharge rate, this allowance can only be made in the part of the site that positively drains the impermeable area. Due to the sensitive nature of the receiving watercourses, we would expect to see a reduction in the existing 1 in 1 year runoff rate from this part of the site to reduce the risk of flooding elsewhere. Discharge from all other parts of the site will need to be limited to the calculated 1 in 2 year Greenfield discharge rate of 2.19 l/s/ha to ensure there is no increase in discharge rates and volumes as a result of the development.
Please note that policy CC/9 of the draft Local Plan 2011 - 2031 states that development will only be permitted where ‘opportunities to reduce flood risk elsewhere have been explored and taken, including limiting discharge of surface water to natural Greenfield rates or lower.’ We therefore consider that discharge rates from all parts of the site should be limited to ‘natural’ Greenfield runoff rate (i.e. 2.19 l/s/ha) if feasible.
The calculated post development runoff rates include the permeable areas of the site (e.g. public open space and playing fields). However, permeable areas of the site can only be included in the calculated discharge rates if it can be demonstrated that these areas will be positively drained to the proposed attenuation features and the attenuation features will be adequately sized to accept runoff from these areas. If this is not feasible, the discharge rates from each catchment areas should be limited to 2.19 litres per second per impermeable hectare. Although the FRA indicates that the proposed drainage strategy will mimic the natural drainage catchments, no evidence has been provided to demonstrate this. A drawing showing the natural drainage routes and catchment areas of the site must be included in the FRA, as well as a drawing showing the proposed drainage routes and discharge points. It should also be demonstrated that all the receiving watercourses are free flowing and able to accept runoff from the development without any increase in flood risk elsewhere.
The FRA indicates that various opportunities to include SuDS in the drainage strategy will be investigated as part of the detailed design. However, we consider that insufficient information has been provided for an outline planning application. An outline drainage strategy should be included in the FRA which demonstrates that the required attenuation storage volume can be provided in each of the catchment areas using SuDS attenuation features.
As no infiltration testing has been undertaken at the site, we consider that insufficient information has been provided to demonstrate that a SuDS management train approach has been used in the drainage strategy and that preference has been given to the use of infiltration drainage over discharge to a watercourse, in accordance with policy CC/9 of the draft Local Plan 2011-2031. Infiltration testing should therefore be undertaken at the site, in accordance with BRE Digest 365. If it is not feasible to access the site to carry out soakage tests before planning approval is granted, a desktop study may be undertaken looking at the underlying geology of the area and assuming a worst-case infiltration rate for that site.
Please note that it is not appropriate to factor climate change allowances into any calculations of Greenfield runoff rates. Any references to the Greenfield runoff rates including an allowance for climate change should therefore be removed from the FRA. Climate change should only be factored into calculations of post-development runoff rates to ensure an allowance for climate change is made in any estimation of the required attenuation storage volumes.
In the eventuality that the applicant is able to submit sufficient satisfactory detail to overturn the above Objection, the Agency will offer further recommendations, informatives and advise in respect of other environmental issues.
Notwithstanding the above Objection, the applicant should consider, possibly within the existing floodrisk assessment, the impact of any cross catchment discharge, from any recipient sewage treatment works outside the sites topographical catchment. It will be necessary for the applicant to demonstrate to the satisfaction of the Local Planning Authority that the development will not result in an increased risk of flooding to existing property.
Yours sincerely
Mr. T.G. Waddams Planning Liaison Officer Direct e-mail [email protected]
Cambridgeshire & Bedfordshire Area, Environment Agency, Bromholme Lane, Brampton, Huntingdon, Cambs. PE28 4NE
www.gov.uk/environment-agency
Awarded to Cambridgeshire and Bedfordshire Area
South Cambridgeshire Hall Cambourne Business Park Cambourne Cambridge CB23 6EA t: 08450 450 500 f: 01954 713149 dx: DX 729500 Cambridge 15 minicom: 01480 376743 www.scambs.gov.uk
Int ernal Memo
To: Ed Durrant Dept: Principal Planning Officer Planning and New Communities
From: Greg Kearney Dept: Health & Environmental Services
Phone: X3145
Date: 11th March 2015
Subject: Town and Country Planning (Environmental Impact Assessment) Regulations 2011
Environmental Impact Assessment Scoping Report / Opinion Request Development of up to 2,350 residential units including affordable housing; retail, use classes A1-A5 (up to 1.04 ha); offices/light industry, use class B1 (up to 5.66ha); community and leisure facilities, use class D1 and D2 (up to 0.92 ha); Two primary schools and one secondary school (up to 11.28 ha), use class D1; three vehicular access points including the extension and modification of Sheepfold Lane, a four arm roundabout provided on A1198/Caxton Bypass and an access point off the A1198, south of the Caxton Gibbet to serve the proposed employment uses; a network of segregated pedestrian and cycle routes; sustainable drainage system and other infrastructure; together with associated earth works, parking, open space, including equipped play, playing fields and landscaping.
Location: Land to the West of Cambourne (Excluding Swansley Wood Farm)
Our Ref: WK 236309 Your Ref S/2903/14/OL
The proposals are considered “EIA Development” under the EIA regulations and a Environmental Statement (ES) has been prepared and accompanies the planning application.
The purposes of the EIA Regulations is to ensure that the environmental effects of a proposed development are fully considered (together with the economic and social benefits of the development), as part of the decision making process before the planning permission is determined. The environmental statement (ES) submitted describes:-
the proposed development, stages and processes involved etc., the main alternatives studied and reasons for final choice,
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the aspects of the environment likely to be affected by the development, the likely impact the development will have on the environment and in particular any significant effects (evaluation, prediction - nature, extent and magnitude of any impact- adverse or beneficial) , consider / describe the measures envisaged / proposed to prevent, reduce or offset / remedy any significant adverse environmental effects (i.e. mitigating measures), the resulting residual impact / effects and proposals to monitor the actual effects if permission is granted.
Executive Summary
The application documents and Environmental Impact Assessment (EIA) with associated Environment Statement (ES) / Appendices are complex and detailed in many respects.
On balance we have no objection in principle to the development proposed.
However, it is our view that the application submissions are lacking sufficient detail / assessment on a number of issues and in particular in relation to traffic noise impacts / effects from the A428 and to a lesser extent the A1198.
The significance of impact / effects associated with traffic noise have not been adequately assessed / considered and the proposed traffic noise mitigation measures are not acceptable and or the mitigation proposed has not been fully justified.
The traffic noise from the A428 in particular has the potential to have a significant adverse impact on the health and quality of life of future residents and the overall quality of the development site generally including the public realm, informal and formal open space and recreational areas. In addition it has not been demonstrated that such significant adverse impacts / effects or just adverse impact as a result of traffic noise have been minimised.
As proposed large areas of the development will be subject to noise levels which we would consider as having a Significant Observed Adverse Effect Level.
In our view this would be contrary to National Planning Policy Framework (NPPF) paragraphs 109, 120, 123, Policy NE/15 of the adopted Local Development Framework 2007 and one of the core planning principles of the NPPF which is to “always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings”.
It is recommended that this outstanding issue be resolved prior to determination and before we can make reasoned and informed decision further assessment, information and or clarifications are required on the noise issues.
These are also required before consideration can be given to the formulation of detailed planning conditions and S106 obligation / requirement requests, which may be required to secure the mitigation of any potential adverse impacts and secure effective service provision.
To address our traffic noise concerns, it is our view that as a minimum consideration should be given to the provision of a substantive environmental noise barrier in the form of an earth bund (similar to those that exist at comparable residential locations in Cambourne along the A428) or acoustic fence / barrier or a combination running continuously along the entire development site boundary with the A428 and possibly
2 along the A1190. The final height and length of such an environmental noise barrier or barrier could only be finalised by detailed noise modelling but to be effective it would have to be of such a height to block the direct line of sight to proposed residential property and habitable rooms. However in considering such a barrier constraints such as existing access roads / tracks and the presence of surface water attenuation ponds / drainage features along and close to the A428 would need consideration. In addition care should be taken when considering such mitigation to ensure the envisaged measures do not make for an unsatisfactory development in other planning respects in terms of urban design or visual impact requirements or loss of open space provision etc.
As this is potentially a fundamental issue the principle of providing such an environmental noise barrier should be explored prior to determination of this application so that the mitigation that could be provided is determined with some degree of certainty or otherwise discounted.
In addition, the following environmental health issues / health determinants should be considered and effectively controlled in order to minimise potential adverse impacts on existing and future local residents, the wider community / living environment to protect the quality of life / amenity and health and which are paramount in facilitating a sustainable high quality development and to ensure there is proper service provision:
Air Quality Noise / Vibration effects on both existing and proposed noise sensitive receptors Contaminated Land Surface Water and Flood Risk including SCDC Awarded Drains Operational Waste / Recycling Provision Artificial Lighting Health Impact Assessment Risk of and from Unexploded Ordnance (UXO)
We have the following detailed comments to make and where appropriate at this stage, officers have recommended draft conditions / informatives for topic assessments that are found to be acceptable in principle, subject to final agreement.
The further assessment, information and or clarifications that are required have been highlighted under the various heading topics, below.
1.1.0 Chapter 10 - Air Quality
I understand Kenny Abere, Scientific Officer (Air Quality), Growth Areas & Planning Team, Environmental Commissioning, Health & Environmental Services (Telephone No: 01954 713070 or email [email protected]) has already provided detailed comments on Chapter 10 - Air Quality. For completeness these were as follows:
We have now taken time to consider the above outline planning - application and will like to comment as follows.
Having given adequate consideration to the submitted Air Quality Assessment Report for residential and other proposed development as detailed in Chapter 10 of the Environmental Statement prepared by the Royal HaskoningDHV, we are pleased to inform you that the submitted AQ report is satisfactory and accepted by this department in spite of sum few assumptions made in the report.
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Therefore, having take note of section 10.34, 10.37, 10.41, 10.42, 10.69, 10.78 and 10.111 of the report, the following conditions are attached for the proposed development whilst it’s also imperative for the applicant to know that the development will be subject to our section 106 agreement considering the nature of the development and its cumulative AQ effect to the district. Relevant monitoring scheme need to be put in place in other to ensure that the future occupiers of the proposed development are not exposed to poor AQ in the long run.
Moreover, we take note of the applicant various proposed dust mitigation scheme in the report with its plan on Low Emission Strategies.
Relevant Conditions
1. Air Quality Construction Condition
All commercial road vehicles used on the construction project must meet the European Emission Standards (commonly known as Euro standards) of Euro 5 during any works that take place from the date of this consent and Euro 6 for any works that takes place from 1 January 2015. In the event of any new European Emission Standards being introduced after 2015 the standards shall be applied to all road vehicles serving the construction project within a period of 2 years after the date of introduction contained within the relevant EU Directive.
All non-road mobile vehicles with compression ignition engines used within the site must comply with emission standards set in EC directive 97/68/EC. Vehicles must meet Stage II limits from the start of contract and from 1 January 2012, meet Stage IIIa and b emission limits.
Exemptions to the above standards (for road and non-road vehicles) may be granted for specialist equipment or for equipment with alternative emission reduction equipment or run on alternative fuels. Such exemptions shall be applied for in writing to the LPA in advance of the use of such vehicles, detailing the reasons for the exemption being sought and clearly identifying the subject vehicles. Exemptions that are granted will be in writing and such vehicles must not be used until written exemption has been received by the applicant.
No vehicles or plant to which the above emission standards apply shall be on site, at any time, whether in use or not, unless it complies with the above standards, without the prior written consent of the local planning authority.
Any diesel powered machines used on, or otherwise serving the site, must be run on ultra-low sulphur diesel (also known as ULSD ‘cleaner diesel’ or ‘green diesel’). "Ultra low sulphur diesel" means fuel meeting the specification within BS EN 590.
(Reason:- In the interest of reducing carbon dioxide emissions, in accordance with South Cambridgeshire (LDF) Development Control Policies (DPD 2007), policy NE/1, NE/2 and NE/3).
2. Renewable Energy
Prior to the commencement of works on the development hereby permitted full details of renewable energy statement for the site, which demonstrates that at least 10% of the buildings’ total predicted energy requirement will be from on-site renewable energy sources, must be submitted to and approved in writing by the Local Planning Authority. The statement shall include the total predicted energy requirement in the form of an Energy Statement of the development and shall set out a schedule of the proposed on-site renewable energy technologies, their respective energy contributions, location, design and maintenance programme.
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The approved renewable energy technologies shall be fully installed and operational prior to the occupation of any approved buildings and shall thereafter be maintained and remain fully operational in accordance with the approved maintenance programme, unless otherwise agreed in writing by the Local Planning Authority.
(Reason:- In the interest of reducing carbon dioxide emissions, in accordance with South Cambridgeshire (LDF) Development Control Policies (DPD 2007), policy NE/1, NE/2 and NE/3).
3. Construction Environmental Management Plan (CEMP) condition – To be incorporated by Greg Kearney
4. Dust Management Plan condition – To be incorporated by Greg
2.1.0 Chapter 11- Noise and Vibration
The following comments have been provided by Greg Kearney, Environmental Health Officer, Health & Environmental Services:
This chapter of the ES assesses the likely significant effects of the Proposed Development in terms of noise and vibration, in particular the potential direct and indirect effects of the development arising from construction phase noise and vibration and operational phase road traffic noise at sensitive receptor locations.
More specifically the noise assessment that considers:
the construction and operational noise and vibration impacts emanating from and associated with the proposed main development, on existing residential and other noise sensitive premises. It considers noise and vibration effects on existing receptors / people who are likely to be exposed to changes in noise levels arising from construction and operation of the scheme including any noise increase on local roads.
the suitability of the site for the proposed development by assessing existing noise impacts on the site from nearby noise sources eg A428 including any impact on any future residents and other noise sensitive premises such as schools and recreational spaces that form part of the development itself
the noise and vibration impacts generated by and inherent to the development and impact on future noise sensitive premises that form part of the development itself
2.2.0 Legislation / Guidance & National and Local Planning Policy Context
The references to statutory, government and industry best practice / guidance, technical standards, codes of practice and the national planning policy framework (NPPF) relating to noise are noted.
However, it is our view that this is incomplete. There is no detailed reference to some very import European / National Legislation, regulations and guidance. These should be included and considered as part of any impact assessment.
Reference should be made to additional relevant legislation and guidance with summaries of their aims, principles, scope and purpose, such as:
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2.2.1 European
The Environmental Noise Directive (2002/49/EC) & Environmental Noise Regulations 2006
The Environmental Noise Regulations (as amended) 2006 implements nationally the EU directive which aims to “define a common approach intended to avoid, prevent or reduce on a prioritised basis the harmful effects, including annoyance, due to the exposure to environmental noise”.
The importance of considering noise impact in land use planning is further reflected in the requirements of the Regulations 2006 and DEFRA’s “Noise Policy Statement for England”, March 2010.
A series of Noise Action Plan including one for Roads (Including Major Roads) have been produced by DEFRA under the regulations.
Noise Action Plan: Roads - A428 Important Areas (IAs) “noise hotspots”
It should also be noted that under the current Noise Action Plans for Major Roads (outside first round agglomerations) strategic noise mapping has identified and designated an area of land immediately adjacent to the Northern Boundary of the development site next to the A428 as an Important Area (IA) “noise hotspot” for the purpose of noise action planning.
Defra’s Noise Action Planning Support Tool has identified this location as Road Important Area: IA Number 5134, Noise Making Authority – Highways Agency, Noise Receiving Authorities – S Cambs DC (New Bungalow and Oak Tree Cottage both St Neots Road, Caxton, Cambridge, CB23 3PH.
The noise action plans are designed to focus on those area worst affected by environmental noise such as traffic and enable local decision makers to address the first aim of the Noise Policy Statement for England (NPSE) “avoid significant adverse impacts on health and quality of life”.
Important Areas are those locations where the top 1% of the worst affected people by traffic noise are located (according to the results of the noise mapping).
No mention is made of this important area within the application but the fact it has been identified indicates that the development site is adjacent to a major traffic noise source the A428 that is considered a priority for action and consideration under noise action planning.
Is should be noted that NPPF National Planning Guidance on Noise under the section What factors influence whether noise could be a concern?, states that :
“Where relevant, Noise Action Plans, and, in particular the Important Areas identified through the process associated with the Environmental Noise Directive and corresponding regulations should be taken into account.”
There are currently several approaches taken to control the impact of noise from road traffic, including planning controls – through the operation of the national, regional and local transport and land use planning system.
Reference should be made to noise action planning and the fact that they acknowledge the importance of land use planning and associated national and local planning policy in controlling the potential adverse impacts of noise associated with new development.
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Therefore it is our view that existing and future ambient traffic noise from the A428 and to lesser extent the AA1198 is an important material consideration as it has the significant adverse effect on the health and quality of life of future residents.
2.2.2 National Planning Policy & NPPF - Planning Practice Guidance – Noise (PPG - N) http://planningguidance.planningportal.gov.uk/blog/guidance/noise/noise-guidance/
The reference to the Noise Policy Statement for England and the concepts of No Observed Effect Level (NOEL) Lowest Observed Adverse Effect Level (LOAEL) Significant Observed Adverse Effect Level (SOAEL) relating to the adverse impacts of noise is noted.
However, since the introduction of the NPPF detailed planning practice guidance has been published which advises on how planning can manage potential noise and vibration impacts in new development.
For construction and operational sound, noise and vibration topics, our main concern and maim shortcoming is that the promoters and noise consultants have made no detailed reference to or interpretation of current Planning Practice Guidance on noise and appear to be using their own interpretation and provide little evidence to justify the way in which significant noise impacts are identified, determined and assessed, for example the numerical noise criteria used in determining the suitability of the site for residential.
Whist there is reference to PPG - N it should clearly referenced including details of the main aims of the guidance. In particular the section titled ‘How to recognise when noise could be a concern?’, and associated table, that summarises a noise exposure hierarchy, based on the likely average response, should be included in full.
The PPG –N noise exposure hierarchy is particularly useful and also provides additional useful information on the interpretation of and outcome descriptors for the concepts of NOELs, LOAELs and SOAELs (increasing noise effect levels) and associated perceptions, examples of outcomes and planning advice / action. It also introduces another effect level, the unacceptable adverse effect level (UAEL). Exposure above a UAEL is to be ‘prevented’.
Any significance of impact assessment needs to fully consider the PPG – N. Full justification and the sources of research, standards and other evidence for the numerical noise criteria detailed and used should be provided.
It is recommended that various noise sources are considered e.g. general anonymous environmental noise sources - road traffic and commercial, industrial trade and business (not anonymous noise sources)
2.3.0 Assessment Methodology and Significance Criteria
The assessment methodologies used for various noise sources and topics are acceptable but we do not agree with some of significance of impact / effect noise criteria that have been used.
The deficiencies in the significance of impact / effect noise criteria used are highlighted in bold below. Further clarifications are required in relation to these deficiencies.
2.4.0 Construction Noise and Vibration Assessment Methodology & Likely Effects
The construction noise and vibration impacts / effects have been considered for existing and also new noise sensitive receptors associated with each construction phase including the 7 proposed phasing of residential units and schools that form part of the development itself having regard to phasing of the construction programme and detailed proposed Phasing Plans.
The assessment considers British Standard [BS] 5228-1 & 2: 2009+A1:2014 “Code of practice for noise and vibration control on construction and open sites – Part 1: Noise & Part 2: Vibration” (BSI, 2014).
This general approach is acceptable but we do not agree with the criteria that have been used for assessing the magnitude and or significance of predicted construction noise effects as detailed in Table 11.4.
It is our view that the criteria that should be used are the construction noise threshold levels based on the BS5228 - ABC Method, as noise levels above these relative to ambient noise levels should be considered significance adverse impact.
Notwithstanding this, at this stage in terms of construction impacts there is general commitment to use the best practical means to reduce noise and vibration effects to a minimum in accordance with mitigation good practice as recommended in BS 5228.
This is welcomed and it is agreed that detailed construction noise impact assessments can only be carried out when detailed construction programmes and activities are finalised and available.
There is also reference to following the conventional approach to good construction noise management by the implementation of a Construction Environmental Management Plan (CEMP), which can include the mitigation measures as detailed which are in accordance with national and industry best practise, standards and technical guidance.
There is reference to obtaining consents under Section 61 of the Control of Pollution Act 1974 (CoPA) for the construction works. This is an option entirely at the discretion of the applicant and or main contactor but there is no guarantee or legal requirement to apply for such consents for construction works.
It is also important to stress that the purpose of such consents is to control noise nuisance and not the safeguarding of amenity, the planning standard. In addition such notices can also be inflexible requiring numerous variation consents and are unlikely to require monititro9ing of impacts.
It is therefore necessary to form a view on whether the powers under CoPA would be adequate and appropriate or whether a more appropriate standard can and should be applied through planning powers. A higher standard of environmental protection should be possible through the planning regime since any requirement to protect amenity would be a more rigorous test than avoiding nuisance.
In this regard, the duration of works is also relevant. It is therefore in our view that it is necessary and appropriate to apply planning conditions for long term construction projects where the development might not otherwise go ahead because the disruption would be so great and prolonged.
Construction impact can be site and phase specific and further details will be required regarding monitoring and specific noise mitigation.
It is therefore recommended that a site wide CEMP condition is imposed for approval prior to commencement of development with each specific phase of the development
8 requiring a phase specific CEMP to demonstrate compliance with the site wide approach that has been approved.
The outline site-wide CEMP would set out the management measures which the applicant will require its contractors to adopt and implement for the construction of the proposed development to avoid, mitigate and manage construction effects on the environment, any existing surrounding communities and new residents. It would be a working document that will be updated periodically, in line with relevant legislation and guidance.
It is also recommended that the CEMP makes reference to CIRIA C741 “Environmental good practice on site guide (4th edition – 2015:C741”and relevant topic issues and general good practice guidance within.
2.5.0 Operational Road Traffic Noise Assessment Methodology & Likely Effects Off – Site
The assessment is acceptable and it is agreed that there will be either no change or a minor long term impact on existing receptors.
The overall finding is that the existing receptors around the site are generally unaffected by noise from road traffic, with a Minor Adverse effect predicted at receptor CN7 Swansley Wood Farm arising from the proximity to the proposed spine road through the development. Due to the minor significance of the effect and the relatively small geographical extent, it is not deemed that specific mitigation is required in order to reduce the effect.
We agree with these findings and proving the spine road location as detailed remains where it is proposed in terms of distance from Swansley Wood Farm no further action is required. Otherwise a spine / primary road noise assessment and details of mitigation measures as appropriate to protect Swansley Wood Farm will be required. .
2.6.0 Completed / Operational Noise Impacts / Effects on Site
2.6.1 Industrial Noise & Sports Pitches and Open Recreational Spaces Assessment & Likely Impacts / Effects
As this is an outline application we agree that that at this stage of the application there is not enough detailed design information or specific noise data to meaningful determine the impact / effects of any noise associated with any proposed industrial, trade, commercial / business or educational premises and uses and sports pitches and open recreational spaces.
However there is reference to the appropriate noise assessment standards that would be used eg BS 4142:2014 – Methods for rating and assessing industrial and commercial sound.
It is noted that such uses and NEAPs and LEAPs will, in certain locations will be close to and integrated with noise sensitive uses such as residential. With regard to the location of any Local Area for Play (LAP), Local Equipped Area for Play (LEAP) or Neighbourhood Equipped Area for Play (NEAP) or similar due regard should be given to the minimum distance Buffer Zones (the space between the facility and the nearest residential property, which is required to minimise disturbance) as detailed in SCDC’s Local Development Framework, Open Space in New Developments, Supplementary Planning Document, Adopted January 2009.
However it is considered that any adverse impact can be identified by noise impact assessment and controlled by the consideration of potential mitigation if required and as appropriate at the detailed design stages. This should be controlled by the imposition of an operational noise condition such as: 9
2.6.2 Draft Condition Operational Noise – Non Residential Use Classes
No development, hereby approved, shall commence in relation to any Development Parcel incorporating uses other than residential dwellings, until an operational noise impact assessment including, where appropriate, a scheme for the insulation of any building(s) or use(s) and associated plant / equipment, and / or noise mitigation measures to minimise the level of noise emanating from the said building(s) or use(s) and associated plant / equipment has been submitted to and approved in writing by the local planning authority.
The approved scheme of insulation / mitigation shall be fully implemented before the relevant use(s), building(s) or plant / equipment are commenced (in relation to uses), occupied (in relation to buildings) or used (in relation to plant / equipment) and shall thereafter be maintained in accordance with the approved details.
REASON: To protect the health and quality of life / amenity of nearby properties in accordance with policy in accordance with National Planning Policy Framework (NPPF) paragraphs 109, 120, 123 and Policy NE/15 of the adopted Local Development Framework 2007.
2.6.3 Suitability of Site for Residential Development
The suitability of the site for residential is considered having due regard to recommended internal and external noise levels in BS 8233: 2014 - Guidance on sound insulation and noise reduction for building which reflect World Health Organisation (WHO) Community Noise Guidelines.
In addition to considering the effect of the Proposed Development on existing sensitive receptor locations, an assessment was also undertaken to predict noise effect at those proposed residential dwellings within the Site which will be occupied in 2028.
The approach undertaken to assesse the suitability of the site for residential is in our view the main deficiency of the noise assessment.
2.6.4 Prediction of Future Noise levels at proposed Residential Premises
The future noise level for each residential development phase has been predicted using the noise model prediction software SoundPLAN, based on the parameter plans and future traffic levels. The noise level for each receiver floor and façade direction (where indicated) have been calculated and is shown in Table 11.27 to Table 11.34. Noise contour plots for the completed development are provided in Appendix 11.1 Figure A11 to A12 and in Figure A17 for the baseline year 2028 without development.
It is concluded that the above tables demonstrate that by applying an assumed 33dB Rw sound insulation standard for example for a standard thermal glazing as detailed in BS8233:2014, Annex G, paragraph G.1 for assessment purposes, the 30dB LAeq,8hr internal night time noise level in bedrooms and the 35 dB LAeq,16hr internal daytime noise level in living rooms and resting spaces would be achieved in all locations within the Site. Therefore the effects on the internal noise levels for medium sensitivity receptors within the Proposed Development are negligible.
These predictions are based on certain assumptions and it stated that a detailed noise ingress calculation following the detailed methodology in BS8233 to determine suitable building envelope sound insulation properties can be completed once site and building designs, layouts and locations are finalised for the development.
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It is also stated that at the detailed design stage may consider mitigation measures for noise sources outside of the buildings and can include;
Increasing the sound insulation of the building envelope; Planning the interior lay-out to avoid nose sensitive rooms being placed on the noise source side, or incorporating buffer zones i.e. toilets, corridors, hallways ; Suitable positioning of buildings on site; Orientation of buildings on site; and Attenuating the sound on its path to the receiver .
It is concluded that the implementation of the mitigation measures outlined above show that the residual noise effects associated with the Proposed Development are negligible.
With fundamentally disagree with this approach.
What the submitted assessment has simplistically done is effectively assume that a robust standard noise insulation scheme achieving a 33dB façade sound reduction index will achieve BS 8233 internal standards. This is technically true and for any indoor space there is, in theory, no restriction to the outdoor noise level as long as the building envelope provides sufficient noise insulation.
However this is likely to result in a very poor outdoor noise environment in the development generally and does not take into consideration that is reasonable for future occupiers to open windows for natural ventilation and it is reasonable for them to do so at any time.
It is our view that significant adverse impact is likely to arise if the internal noise levels cannot be achieved with a partially open window.
For those proposed residential façades and habitable rooms that are predicted to be most affected by road traffic noise an integrated design mitigation approach to “design out” traffic noise impact to negate the need to have a noise insulation scheme is recommend in the first instance and to protect external amenity areas.
The traffic noise from the A428 in particular has the potential to have a significant adverse impact on the health and quality of life of future residents and the overall quality of the development site generally including the public realm, informal and formal open space and recreational areas. There fore there is a big question over the impact of noise on the functional use of the proposed playing fields next to the A428 and whether they are actually fit for purpose.
In addition it has not been demonstrated that such significant adverse impacts / effects or just adverse impact as a result of traffic noise have been minimised.
In the hierarchy of mitigation measures reducing the noise at source (which is advocated by SCDC’s Design Guide SPD and BS 8233) should be considered in the first instance, which in this case is the dominant traffic noise from the A428 an to a lesser extern the A1198.
However, it is appreciated that it is not always possible to mitigate ambient external noise fully to negate the need for a noise insulation scheme for the building fabric. It is therefore likely that a noise insulation scheme incorporating an acoustically treated purge / rapid ventilation system (mechanical or passive, to achieve 2 to 4 air changes per hour) will be required when the recommended “Indoor ambient noise levels for dwellings” in BS 8233: 2014, are exceeded with a partially open external window (eg 35 dB LAeq,T for living/dining rooms during the day and 30 dB LAeq,T in bedrooms at night).
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These internal levels would equate to external free-field noise levels of 48 to 50 dB – day time and 43 to 45 dB night time respectively (assuming a 13 or 15dB reduction across open window & if near field these noise levels would need to be 3dB lower).
In some house types, some rooms that are identified as requiring acoustically treated ventilation (whether passive or purge) may have a dual aspect. If this is the case, it is assumed that ventilation would be provided through the window that is the least affected by noise and, in this circumstance, the ventilation requirements would be driven by the predicted noise level at this window.
In addition, external amenity areas should not be provided where noise modeling predicts noise levels above 50dB LAeq (free field) in any part of an external private amenity area e.g. private / communal garden, balconies between 0700hrs and 2300hrs.
In relation to this matter our comments above under Legislation and Guidance and in particular the NPPF - Planning Practice Guidance – Noise (PPG - N) and Noise Action Planning above are relevant.
In light of the NPPF and associated published guidance it is disappointing that the concepts of noise effect levels NOEL, LOAEL and SOAEL are not given more detailed consideration, explanation or clear justification for the noise criteria detailed / used and how they accord with PPG-N and planning advice.
These noise effect levels and associated likely impacts are difficult concepts and should be explained in a language and manner that is readily understandable for the benefit of all and in particular the public.
It is recommend that this section is expanded on and evidence should be provided for the choice of numerical noise levels used and source eg WHO daytime or night time guidance?
2.6.5 Table 11.13: Definitions of Terms Relating to the Sensitivity of Receptors
We disagree that uses such residential accommodation, private gardens, hospital wards, care homes should be considered as receptors of medium sensitivity.
These are highly sensitive receptors and justification should be provided for determining them as having medium sensitivity similar to schools, universities, research facilities, and temporary holiday accommodation?
It is our view that most appropriate approach to assessing the suitability of the site for residential the development site should be to as follows:
i. Assess the development site as an open site as it is now and at a future complete year (with no development of site) and report the existing and future distribution of noise levels across / throughout the site at various receptor heights in accordance with in BS 8223 day LAeq,16h (07.00 to 23.00) and night LAeq,8h (23.00 to 07.00) periods.
ii. Assign a PPG–N noise exposure effect level / hierarchy category to the site having regard to other useful information on the interpretation of and outcome descriptors for the concepts of NOELs, LOAELs and SOAELs (increasing noise effect levels) and associated perceptions, examples of outcomes and planning advice / action.
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iii. Consider / describe the measures envisaged / proposed to prevent, reduce or offset / remedy any significant adverse environmental effects (i.e. mitigating measures), the resulting residual impact / effects
In accordance with BS 8233 for noise sources outside the building, the initial appraisal should take account of the options for: a) location of the site in relation to the noise source(s); b) reduction of noise at source; c) positioning of buildings on site; d) orientation of buildings on site; e) provision of barriers; f) increasing the sound insulation of the building envelope; and g) re-planning the interior layout of the building.
Having regard to the various noise predictions reported in the noise chapter it is our view that significant adverse impact / effects is likely to arise internal and externally at future residential premises in the following zones:
Zone and Direction Floor Level Dominant Noise Source SCDC SOAEL Of Façade Criterion Exceeded? Day Time Night Time A1(a) N GF A428 Yes Yes F1 A1(a) NE GF A428 Yes Yes F1 A1(b) W GF A428 Yes Yes F1 F2 A1(b) NE GF A428 Yes Yes F1 F2 A1(b) S GF A428 & Internal Roads Yes Yes F1 F2
A2 (c) NE F1 A428 Yes Yes F2 B (e) NW Internal Roads Yes Yes
C(a) NW GF A1198 & Internal Roads Yes Yes F1 C(c) W GF A1198 & Internal Roads Yes Yes F1 F2
D(a) SW GF A1198 Yes Yes F1
D(b) SE GF Internal Roads Yes Yes F1 F2
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E(b) SE GF Internal Roads Yes Yes F1 F2
F(a) N GF A428 Yes Yes F1 F2 F(b) N GF A428 Yes Yes F1 F2
G(a) W GF A1198 Yes Yes F1 H S GF F1 F2 H E GF F1 F2 Northern Playing Fields
2.6.6 External Noise levels
As stated above consideration should also be given to external noise levels in not only private external amenity area but also in the general public realm and informal and formal open spaces including the recreational areas such as the proposed prosed playing fields and athletic track close to the A428.
Further consideration should be given to attributing numerical noise values or a value range to equivalent to ascertain appropriate significant adverse impact assessment criteria.
Values should be given to noise levels measured on an open site at the position of the proposed dwellings and pubic realm. The World Health Organisation (WHO) suggest that to protect the majority of people from moderate annoyance during the day time outdoor noise levels should not exceed 50dB LAeq. This in our view should be considered as the LOAEL for residential development subject to transportation noise. At sites where daytime levels from transportation noise are less than 50 dB LAeq noise is unlikely to be a consideration and should be considered approaching NOEL. Where the external noise is 50 dB LAeq internal noise levels (open windows) will be acceptable (35-40 dB LAeq).
WHO guidance also states that to prevent the majority of people becoming seriously annoyed during the daytime the sound pressure level on balconies, terraces and outdoor living areas should not exceed 55 dB LAeq. This should be considered the SOAEL for gardens and outdoor living spaces and in particular private amenity spaces..
2.6.7 Consideration of Noise Mitigation / Attenuation Measures
As stated as we do not agree with the assessment that has been undertaken for assessing suitability of the site for residential and we do not agree with proposed mitigation measures.
Development should not be permitted in areas which are, or are expected to become, subject to unacceptably high levels of noise in the foreseeable future unless adequate levels of protection 14 can be secured as part of the master planning, integrally designed into the development and or acceptable and sufficient mitigation off site can be secured.
Engineering mitigation measures to residential internal and external areas should be the last resort and to ensure a high quality design from the outset, environmental pollution constraints should be considered at the earliest opportunity in the EIA planning process as this may result in abortive works further in design process.
A number of measures can be used to control the source of or limit exposure to construction and operational noise. Such measures should be proportionate and reasonable. Possible noise control measures include the following hierarchy:
i. control at the source (measures to reduce noise emissions at source such a quiet plant, noise insulation of buildings, plant enclosures or quiet road surfaces and or noise barriers/ earth bunds);
ii. control of the transmission path (adequate distance separation, building location, form and orientation, screening / noise barriers);
iii. control of noise at receiver (internal planning such as non-habitable rooms providing a buffer, orientation of noise sensitive rooms and balconies and gardens way from noise by barrier dwelling blocks, single aspect courtyards schemes and staggered terraces, careful fenestration, noise insulation scheme for the building envelope of noise sensitive buildings and also buildings generating noise, reduced external amenity, acoustic ventilation)
iv. by controls over the operations that generate the noise (such as controls over the hours of operation, deliveries / collections, reduced traffic speeds).
2.6.8 Site Suitability for Other Development Assessment- Schools
Impact of Environmental Noise on the School Use
In terms of the influence of existing ambient noise on the suitability of the site for a school the proposals will need to meet the minimum acoustic standards for schools as set out in section E4 of Building Regulations AD- E, Resistance to the passage of sound, that is compliance with ‘Building Bulletin 93: Acoustic Design of Schools - Performance Standards’ (BB93), 2014.
This should be acceptable.
2.6.9 Conclusion on Suitability of Site For Residential
In our view the significance of impact / effects associated with traffic noise have not been adequately assessed / considered and the proposed traffic noise mitigation measures are not acceptable or are inadequate and or the mitigation proposed has not been fully justified.
The traffic noise from the A428 in particular has the potential to have a significant adverse impact on the health and quality of life of future residents and the overall quality of the development site generally including the public realm, informal and formal open space and recreational areas. In addition it has not been demonstrated that such significant adverse impacts / effects or just adverse impact as a result of traffic noise have been minimised.
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In our view that this would be contrary to National Planning Policy Framework (NPPF) paragraphs 109, 120, 123, Policy NE/15 of the adopted Local Development Framework 2007 and one of the core planning principles of the NPPF which is to “always seek to secure high quality design and a good standard of amenity for all existing and future occupants of land and buildings”.
It is recommended that this outstanding issue be resolved prior to determination and before we can make reasoned and informed decision further assessment, information and or clarifications are required on the noise issues.
These are also required before consideration can be given to the formulation of detailed planning conditions and S106 obligation / requirement requests, which may be required to secure the mitigation of any potential adverse impacts and secure effective service provision.
Further advice can be obtained from Greg Kearney, Environmental Health Officer, Health & Environmental Services- Telephone No: 01954 713145 or email [email protected]
3.1.0 Ground Conditions and Contaminated Land
The following comments have been provided by Claire Sproats Scientific Officer, Contaminated Land, Growth Areas & Planning Team, Environmental Commissioning, Health & Environmental Services - Telephone No: 01954 713213 or email [email protected]:
Contaminated Land Ref: EH/CS/255302
I wish to confirm that I have a received a copy of the above application, in particular the Land Quality Preliminary Risk Assessment by Royal HaskoningDHV dated August 2014 (forming Appendix 12 of the Environmental Statement by Barton Wilmore dated December 2014), and have considered the implications of the proposals.
The above report has identified the risk of potential contamination from uses of the site as a farm and a former airfield. Given the proposed sensitive end use (residential), the report therefore highlights the need for intrusive ground investigation prior to the commencement of any site development works, which I am in agreement with. I welcome the proposal to engage with regulators pre-site investigation, to agree a scope of works.
Therefore I recommend that no development approved by this permission shall be commenced, unless otherwise agreed, until: a) The application site has been subject to a detailed scheme for the investigation and recording of contamination and remediation objectives have been determined through risk assessment and agreed in writing by the Local Planning Authority. b) Detailed proposals for the removal, containment or otherwise rendering harmless any contamination (the Remediation method statement) have been submitted to and approved in writing by the Local Planning Authority. c) The works specified in the remediation method statement have been completed, and a Verification report submitted to and approved in writing by the Local Planning Authority, in accordance with the approved scheme. d) If, during remediation works, any contamination is identified that has not been considered in the remediation method statement, then remediation proposals for this material should be agreed in writing by the Local Planning Authority. 16
Reason – To ensure that risks from land contamination to the future users of the land and neighbouring land are minimised, together with those to controlled waters, property and ecological systems, and to ensure that the development can be carried out safely without unacceptable risks to workers, neighbours and other offsite receptors in accordance with Policy DP/1 of the adopted Local Development Framework 2007
Please return a copy of the decision notice regarding this application, quoting the Department’s reference, when it has been determined.
4.1.0 Chapter 12 - Hydrology and Water Resources
Pat Matthews, Drainage Manager, Health & Environmental Services, SCDC has provided the following comments:
The proposals and scope appear acceptable subject to approval by the Environment Agency who we understand have already advised on rates of run off and standards.
It is expected that the detailed design will demonstrate benefit to the downstream watercourses / communities including the use of sustainable urban drainage systems to the standards recommended by Cambridgeshire County Council.
Under the terms of the Council’s Land Drainage Byelaws no increase in the rate or volume of flow will be allowed without the prior consent of the Council. It should also be noted that Land Drainage Byelaw consent will be required for all connections to the award drain Bourn Brook.
Further advice can be obtained from Pat Matthews, Drainage Manager, Health & Environmental Services, SCDC - Telephone No: 01954 713472 or email [email protected]
5.1.0 Waste Generation and Management / Waste and Recycling
I understand that Kylie Laws, Waste Recycling and Minimisation Officer, Growth Areas & Planning Team, Health & Environmental Services- Telephone No: 01954 713192 & email [email protected], has already provided you with detailed comments in relation to this topic.
6.1.0 Chapter 14 - Artificial Lighting
This chapter assesses the likely significant effects of the proposed development in terms of artificial lighting impacts associated with the construction and operational phases and its effects at sensitive receptor locations.
The assessment has been undertaken in line with best practice guidance and the Institute of Lighting Professionals, Guidance on Undertaking Environmental Lighting Impact Assessments (ILP, PLG04, 2013). This has included consideration of existing environmental lighting zones in the area, as reported in Appendix 14 Baseline Lighting Assessment and any impacts on these.
When comparing the existing site and its lighting environment against the proposed development associated lighting requirements, by virtue of the nature, size and location of the proposals there will be an increase in the lighting levels witnessed on site, resulting in a change in the existing lighting environment.
However we agree with the conclusions that providing the generic mitigation measures as detailed are implemented to met lighting levels in accordance with industry best practice and
17 guidance, the potential effects on surrounding sensitive receptors from light spill / trespass and glare are likely to be negligible to minor adverse.
However any final detailed lighting schemes for the development or for each phase should be submitted for approval and the following condition should be imposed:
6.1.1 Recommended artificial lighting condition:
Prior to the commencement of the development or concurrently with each reserved matters application an artificial lighting scheme, to include details of any external lighting of the site such as street, floodlighting, security / residential lighting and an assessment of impact on any sensitive residential premises on and off site, shall be submitted to and approved in writing by, the Local Planning Authority. The scheme shall include layout plans / elevations with luminaire locations annotated, full isolux contour map / diagrams showing the predicted illuminance in the horizontal and vertical plane (in lux) at critical locations within the site and on the boundary of the site and at future adjacent properties, including consideration of Glare (direct source luminance / luminous intensity in the direction and height of any sensitive residential receiver) as appropriate, hours and frequency of use, a schedule of equipment in the lighting design (luminaire type / profiles, mounting height, aiming angles / orientation, angle of glare, operational controls) and shall assess artificial light impact in accordance with the Institute of Lighting Professionals “Guidance Notes for the Reduction of Obtrusive Light GN01:2011” including resultant light intrusion / trespass, source glare / luminaire intensity and building luminance.
The approved lighting scheme shall be installed, maintained and operated in accordance with the approved details / measures unless the Local Planning Authority gives its written consent to any variation.
REASON: To protect the character and appearance of the area and the amenity of existing and future residential properties in accordance with National Planning Policy Framework (NPPF) paragraphs 120, 125 and Policy NE/14 of the adopted Local Development Framework 2007.
Environmental Health considers the impact of artificial light on residential premises as it can affect health and quality of life and can be determined a statutorily nuisance. These comments do not consider in detail any potential impacts / effects on other environs / receptors such as businesses, landscape / visual, ecological (fauna behaviour & breeding), drivers on any public highway, secured by design requirements or other interested organisations such as Astronomy Organisations (sky glow). These effects should be considered by respective specialists in those areas.
Further advice can be obtained from Greg Kearney, Environmental Health Officer, Growth Areas & Planning Team, Health & Environmental Services- Telephone No: 01954 713145 or email [email protected]
7.1.0 Health Impact Assessment (HIA) / Socio-Economic Issues
In relation to this topic I understand that Iain Green, Public Health Specialist, Health & Environmental Services has already provided you with detailed comments.
8.1.0 Cumulative Effects Assessment
The approach that has been followed in relation to cumulative impacts is acceptable for the various environmental health related topics
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9.1.0 Additional Issues
9.1.1 Potential Operational Odour Generation & Control
The ES does not appear to consider the potential impact of odour generation associated with the development any proposed non-residential uses such as food premises or similar have the potential to generate odour. This is relevant to any proposed retail, trade, business, community and educational uses.
Depending on the source and nature, odour can be a prevalent problem at low levels of concentrations and has the potential to impact on a wide area and affect amenity.
However, the odour impacts are likely to be negligible if mitigation measures are implemented to minimise impact. It will be necessary to adequately discharge and or abatement of odours to ensure odour nuisance is not caused and to protect the amenity of neighbouring premises and this should be controlled by condition.
Operational Odour recommended conditions: i. Within any reserve applications for development parcels with industrial, trade, business and community premises or similar, a scheme for and details of equipment for the purpose of extraction and/or filtration and/or abatement of fumes and or odours, shall be submitted to and approved in writing by the local planning authority. The approved extraction/filtration/abatement scheme shall be installed before the use is commenced and shall be retained thereafter. Any approved scheme / system shall not be altered without prior approval.
Any approved fume filtration/extraction system installed shall be regularly maintained in accordance with manufacturer specification to ensure its continued satisfactory operation to the satisfaction of the Local Planning Authority.
It is suggested that documentary evidence including receipts, invoices and copies of any service contracts in connection with the maintenance of the extraction equipment, is kept, preferably at the premises and is available for inspection by officers of the Local Planning Authority, to facilitate monitoring of compliance with this condition.
Reason: To protect the amenity of nearby residential premises in accordance with National Planning Policy Framework (NPPF) paragraphs 120 and policy DP/3 Development Criteria of the adopted Local Development Framework 2007 ……………?
Greg Kearney Environmental Health Officer Health & Environmental Services
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TR110 (November 2011)
Developments Affecting Trunk Roads and Special Roads Highways Agency Response to an Application for Planning Permission
From: Divisional Director, Network Delivery and Development, Eastern Region, Highways Agency.
To: South Cambridgeshire District Council
Council's Reference: S/2903/14/OL
Referring to the notification of a planning application dated 14 January 2015, your reference S/2903/14/OL, in connection with the A428, application for the development of up to 2,350 residential units including affordable housing; retail, offices/light industry, community and leisure facilities, primary and secondary schools, a four arm roundabout provided on A1198/Caxton Bypass and an access point off the A1198, south of the Caxton Gibbet, a network of segregated pedestrian and cycle routes and other infrastructure, Land to the West of Cambourne (Excluding Swansley Wood Farm), notice is hereby given under the Town and Country Planning (Development Management Procedure) (England) Order 2010 that the Secretary of State for Transport:-
a) offers no objection;
b) advises that planning permission should either be refused, or granted only subject to conditions
c) directs conditions to be attached to any planning permission which may be granted;
d) directs that planning permission is not granted for an indefinite period of time;
e) directs that planning permission not be granted for a specified period (see Annex A).
(delete as appropriate)
Signed by authority of the Secretary of State for Transport
Date: 2 February 2015 Signature:
Name: Eric Cooper Position: ASSET DEVELOPMENT TEAM
The Highways Agency: Woodlands, Manton Lane Bedford MK41 7LW Annex A
Page 1 Reason for the Direction at e) above The transport assessment submitted with this application is extensive and complex. The Highways Agency requires more time to review those aspects relating to the potential impacts upon the A428 trunk road before we are able to offer meaningful views on the application.
The direction remain in effect until 20 March 2015
Page 2 South Cambridgeshire Hall Cambourne Business Park Cambourne Cambridge CB23 6EA t: 03450 450 500 f: 01954 713149 dx: DX 729500 Cambridge 15 minicom: 01480 376743 www.scambs.gov.uk
Memo
To: Edward Durrant, Principal Planning Officer From: Iain Green, Environmental Health Officer (Public Health Specialist) Date: 04 March 2015
Proposal: Land to the West of Cambourne (Excluding Swansley Wood Farm) - Development of up to 2,350 residential units including affordable housing; retail, community and leisure facilities, Two primary schools and one secondary school etc. Location: Cambourne/Caxton Applicant: Taylor Wimpey UK Ltd & Bovis Homes Ltd Reference: S/2903/14/OL
Thank you for forwarding the above planning application for Land to the West of Cambourne (Excluding Swansley Wood Farm) - Development of up to 2,350 residential units including affordable housing; retail, community and leisure facilities, Two primary schools and one secondary school etc. As per the Council’s Supplementary Planning Document on Health Impact Assessment (HIA SPD) I have reviewed the outline application using the HIA Review Package checklist contained in Appendix 3. The outcome of that assessment is that the Health Impact Assessment as submitted has been assessed as grade B. Grade B meets the required standard of the HIA SPD policy (only HIA’s graded A or B are acceptable).
My comments on the HIA are contained in the HIA Review checklist attached to this memo and should be read in conjunction with this memo.
Results of review of Health Impact Assessment using the review package for health impact assessment reports of development projects
Planning application description Land to the West of Cambourne (Excluding Swansley Wood Farm) - Development of up to 2,350 residential units including affordable housing; retail, community and leisure facilities, Two primary schools and one secondary school etc. Planning reference number: S/2903/14/OL
Reviewing officer: Iain Green
Date of review: January 2015
The assessment will produce an overall grade for the HIA as follows: A Relevant tasks well performed, no important tasks left incomplete, only minor omissions and inadequacies B Can be considered satisfactory despite omissions and/or inadequacies C Parts are well attempted but must, as a whole, be considered just unsatisfactory because of omissions or inadequacies D Not satisfactory, significant omissions or inadequacies, some important task(s) poorly done or not attempted. N/A Not applicable
Review Area Description Score Overall score for review area 1 Context B Score for review area 1.1 Site description and policy framework B Score for review area 1.2 Description of project B Score for review area 1.3 Public health profile B
Overall score for review area 2 Management B Score for review area 2.1 Identification and preparation of health impacts B Score for review area 2.2 Governance B Score for review area 2.3 Engagement B
Overall score for review area 3 Assessment B Score for review area 3.1 Description of health effects A Score for review area 3.2 Risk assessment B Score for review area 3.3 Analysis of distribution of effects C
Overall score for review area 4 Reporting B Score for review area 4.1 Discussion of results C Score for review area 4.2 Recommendations B Score for review area 4.3 Communication and layout B
Total score for review of HIA Overall grade B
Review area, categories and sub-categories Score 1 Context1 B 1.1 Site description and policy framework B 1.1.1 The report should describe the physical characteristics2 of the project3 site and A the surrounding area. Comments Given in section 2.3
1.1.2 The report should describe the way in which the project site and the A surrounding area are currently used.4 Comments Given in section 2.3
1.1.3 The report should describe the policy context and state whether the project accords with significant policies5 that protect and promote wellbeing and public D health and reduce health inequalities. Comments No policies have been given in the HIA and there are no references to other documents such as the D&A or Planning statement which might contain relevant policies.
1.2 Description of the project B 1.2.1 The aims and objectives of the project should be stated and the final A operational characteristics of the project should be described.6 Comments Given in section 2
1.2.2 The estimated duration of the construction phase, operational phase, and B where appropriate, decommissioning phase should be given. Comments Not given precisely but there is a projected housing trajectory from which the construction phase can be derived.
1.2.3 The relationship of the project with other proposals should be stated. C Comments Relationship to the existing Cambourne development has been given, I would have expected to have seen an acknowledgement of the developments happening in St Neots (Wintringham Park and Loves Farm) which may affect traffic on the A428.
1.3 Public Health Profile B 1.3.1 The public health profile should establish an information base from which requirements for health protection, health improvement and health services can A be assessed. Comments A comprehensive profile has been given in section 3
1 If the HIA is prepared in conjunction with an Environmental Impact Assessment, or other studies, elements of this description may be shared with those other studies.
2 The physical characteristics may include the location, design, size and an outline of the area of land take during the construction and operation phase. Presentation or reference to diagrams, plans or maps will be beneficial for this purpose. Graphical material should be easy to understand without having any knowledge about planning and design.
3 The review package uses the term project to mean the execution of construction works or of other installations or schemes; or other intervention in the natural surroundings and landscape including those involving the extraction or mineral resources
4 Does the site description indicate whether the site and surrounding area are used, either formally or informally, and if so who by?
5 The policies may be local, regional, national or international policies or they may be sector specific.
6 Has a do nothing option and other alternatives to the project been described? Does the report also describe the primary advantages and disadvantages to health of the proposal and alternatives? It should be noted if no alternatives are being assessed.
1.3.2 The profile should identify vulnerable population groups. The profile should describe, where possible, inequalities in health between population groups and D should include the wider determinants of health.7 Comments There is no mention of vulnerable groups, so it is unclear if there aren’t any vulnerable groups in Cambourne or that they have just not been identified within the data available.
1.3.3 The information in the profile should be specific about the timescale; the geographic location and the population group being described and links should C be made with the proposed project.8 Comments A demographic profile for the existing Cambourne development has been given and it is fair to assume the new development will follow this profile. Little consideration has been given to the existing farm on the site.
2 Management B 2.1 Identification and prediction of health impacts B 2.1.1 The report should describe the screening and scoping stages of the HIA and A the methods used in these stages.9 Comments Screening and scoping was consulted separately through a request for an HIA screening and scoping opinion which was commented on and agreed prior to submission. It would have been helpful to have included the HIA Scoping report and opinion as an appendix to the HIA.
2.1.2 A description of how the quantitative evidence was gathered and analysed B (where appropriate) should be given and its relevance to the HIA justified.10 Comments Partly given in the HIA Section 1.28-1.31. national data e.g. ONS and PHE data has been used which is relevant and appropriate.
2.1.3 A description of how the qualitative evidence was gathered and analysed B (where appropriate) should be given and its relevance to the HIA justified.10 Comments Partly given in the HIA Section 3.3 using qualitative learning from Cambourne data which is relevant and appropriate.
2.2 Governance B 2.2.1 The governance process for the HIA should be described.11 C Comments Partly given in section 1.15-1.17.
2.2.2 The terms of reference for the HIA should be available to the reader and the geographical, temporal and population scope of the HIA should be made B explicit. Comments Covered in 1.11 and in 1.29 but it is not made explicit that this is the Terms of Reference for the HIA
7 People’s health is influenced by the conditions in which they live. Health determinants are the personal, social, cultural, economic and environmental factors that influence the health status of individuals or populations. These include, but are not limited to, factors such as income, employment, education, social support and housing.
8 Does the profile include consideration of the future profile of the population
9 Tools or checklists are methods mostly used to screen for potential health impacts. The scoping stage often includes consultation, workshop, matrices, specific checklists, literature review, expert advisory panels, etc. Sometimes the scope of the HIA is predetermined by the commissioner of the HIA; do the authors justify the use of particular methods?
10 Is the use of any statistical techniques adequately justified?
11 Was the HIA guided and scrutinised by a steering group? What was the membership of the steering group? Which organisation has final ownership or/accountability for the report and its findings? Was the commissioner’s relationship to the HIA process including the development of findings and reporting of the HIA made explicit?
2.2.3 Any constraints in preparing the HIA should be explained.12 B Comments The application is an outline application and therefore the HIA is limited – outlined in section 1.11
The existing traffic congestion during peak times on the A428 is an existing constraint and should have been assessed and addressed within the HIA
2.3 Engagement B 2.3.1 The report should identify relevant stakeholder groups, including organisations responsible for protecting and promoting health and wellbeing that should be B involved in the HIA. Comments Outlined in section 1.27 and reference is made to the Statement of Community Involvement, including consultation with NHS Property Services regarding the capacity of the existing Primary Health Care provision (section 1.21)
2.3.2 The report should identify vulnerable population groups that should be involved C in the HIA.13 Comments Outlined in Section 4 and partially outlined in section 1.26 but no vulnerable groups have been identified. Learning from Cambourne has been mentioned in section 3.3-3.7 however vulnerable populations identified in the learning from Cambourne report do not appear to have been consulted with regards to this application.
2.3.3 The report should describe the engagement strategy for the HIA.14 B Comments Reference is given to the Statement of Community Involvement.
3 Assessment B 3.1 Description of health effects A 3.1.1 The potential health effects of the project, both beneficial and adverse should A be identified and presented in a systematic way.15 Comments Well laid out and concise health effects of the project has been given in section 5
3.1.2 The identification of potential health impacts should consider the wider determinants of health such as socio-economic, physical, and mental health A factors. Comments The HUDU model has been used which is appropriate
3.1.3 The causal pathway leading to health effects should be outlined along with an B explanation of the underpinning evidence.16
12 This might include limitations of method or availability of evidence, for example time, resources, accessibility of data, non-availability/involvement of key informants and stakeholders. It might also describe any limitations in the scope of the HIA.
13 Does the report describe how stakeholders were identified and whether key informants have been selected as representatives?
14 Does the report describe how the stakeholder groups, key informants, other stakeholders and citizens who were involved were involved? There may be reasons for not engaging or consulting members of the public. If so, are these provided and adequately explained? Does the report explain the engagement methods, and their timing, e.g. were leaflets, meetings, interviews, etc. used and at what stage and for which stakeholder groups? 15 Does the identification of impacts consider short-term, long-term (and are these timescales defined?), direct and indirect impacts on health and wellbeing? Does the identification of health impacts distinguish between the construction phase, the operational phase and where relevant the decommissioning phase?
16 The potential health effects may be presented in diagrams, which show the causal pathways and changes in intermediate factors by which the project may affect population health, or may be descriptive.
Comments Outlined in section 5. Some evidence to support the findings has been given. The main comments on each health impact domain are as follows:
Air Quality - Construction I agree with the findings of this assessment, however, it would have been helpful to have included a brief summery of the data contained in the ES chapter 10 to confirm that the impact is not adverse. I would recommend that the mitigation measures contained within Section 10 of the ES are conditioned as part of any consent.
Air Quality - Operation I agree with the findings of this assessment, however, I would suggest confirmation is sought from the Scientific Officer (Air Quality) at SCDC to confirm the findings of the assessment.
Noise - Construction I agree with the findings of this assessment. I would recommend that the mitigation measures contained within Chapter 11 of the ES are conditioned as part of any consent.
Noise – Operation I agree with the findings of this assessment, however the commercial area near the A428 roundabout may be a source of adverse noise and therefore depending on the precise use of this land additional noise mitigation measures may be needed. Therefore I would suggest confirmation is sought from the EHO (Planning Specialist) at SCDC to confirm the findings of the assessment and also to suggest mitigation measures if needed.
Transport - Construction I agree with the findings of this assessment, however, the assessment should have considered the connectivity to the rest of Cambourne and the vehicular access to the business area (near the A428 roundabout) from the rest of Cambourne.
I would recommend that the mitigation measures contained within Chapter 9 of the ES are conditioned as part of any consent.
Transport – Operation I agree with the findings of this assessment. I would recommend that the mitigation measures contained within the Transport Strategy are conditioned as part of any consent.
Socio-economic - Construction I agree with the findings of this assessment.
Local Demography and Socio-economic structure – Operation I agree with the assessment, however there is no detail regarding different housing and design layouts for different ages of the population, I would expect this to be included in any reserved matters or design coding.
I am concerned over the proposal to build a second separate secondary school rather than expand the existing school, there is the possibility to build in a resentment culture and associated “gang” type behaviour from the outset with the schools being so close together. I would recommend that a condition is attached to any consent requiring the layout and design of housing plots, street layout etc. to be agreed by the LPA prior to commencement of work on site.
Housing - Operation There is nothing in the Health Impact Assessment which relates to housing mix or tenures. The SCDC Policy requires 40% affordable housing (depended on viability) therefore I would have expected to have seen an assessment accordingly, particularly with reference to the findings of the community engagement listed in section 4.10 of the HIA which picks out a key theme of the “importance of a mix of housing”
Housing mix (tenure and no of bedrooms) has an effect on population demographics and therefore has an effect on the health demand with that area, the housing mix needs to be agreed as soon as possible in order for it to be factored into section 106 discussions on capital and revenue requirements for Primary Care
Services and Amenities and Leisure - Operation I agree with the findings of this assessment, however due to the pressures on local primary care I would have expected to have seen Health Facilities prominent in the list, although this is covered in section 5.37.
I agree that there will need to be provision for additional Primary Care facilities associated and therefore this should be included within any Section 106 agreement. I have concerns that the approach to revenue cost based on a zero migration from within Cambridgeshire to South Cambridgeshire is too simplistic and therefore I suggest advice is sought from NHS Property Services, The Cambridgeshire and Peterborough Clinical Commissioning Group and NHS England before agreeing the detailed section 106 requirements for Health Care Provision. In addition there may be a need for additional Health Visitors to service the increased population which, from October 2015, will be the responsibility of the Cambridgeshire County Council Public Health Department to commission and therefore I would suggest they are consulted as part of the Section 106 negotiations.
Income and employment opportunities - Operation I agree with the assessment, however increasing direct, indirect and induced socio- economic opportunities is only one factor in facilitating the creation of a healthy, vibrant and cohesive community, Community development approaches are also necessary.
Healthy Urban Design – Operation Governance This section is inadequate in that the section should include an assessment of governance and ownership of community facilities e.g. community buildings, open space, sports and play provision. The site is located within the Caxton Parish rather than the Cambourne Parish and as such in order to foster community cohesion discussion should take place at the earliest opportunity as to Governance of Community assets between the two parishes.
Transport and connectivity I agree with the assessment however as part of further work on this application I would expect to see more indicative arrangements for including public transport within the development site including location of bus stops etc.
I am concerned that there is no easy vehicular access to the Cambourne West site from the existing Cambourne development. An access route through the existing business park should be considered.
Services There should be an acknowledgement of the need for a local centre which is included within the masterplan but has not been referenced within the HIA. The will affect distances to services rather than relying on the existing provision within Cambourne.
In addition I would recommend that the location of the local centre/retail space is carefully considered in relation to the availability of takeaway food and proximity to both the high schools and primary schools, several Councils are using a distance of 400m as a mimimum distance from any fastfood outlet to schools. 400m is is thought to equate to a walking time of approximately five minutes. However, in Brighton and Hove this was found to be inadequate to cover the areas actually used by pupils: an 800m radius is used as it covers significantly more lunchtime journeys.
In addition recent research “Associations between exposure to takeaway food outlets, takeaway food consumption, and body weight in Cambridgeshire, UK: population based, cross sectional study” Burgoine Thomas, Forouhi Nita G, Griffin Simon J, Wareham Nicholas J, Monsivais Pablo. BMJ 2014; 348 :g1464 suggests exposure to takeaway food outlets was positively associated with consumption of takeaway food. Among domains at home, at work, and along commuting routes, associations were strongest in work environments, with evidence of a dose- response effect.
Housing As previously discussed there is nothing in the Health Impact Assessment which relates to housing mix or tenures. The SCDC Policy requires 40% affordable housing (depended on viability) therefore I would have expected to have seen an assessment accordingly, particularly with reference to the findings of the community engagement listed in section 4.10 of the HIA which picks out a key theme of the “importance of a mix of housing”
Environment I agree with the assessment.
Equity I agree with the assessment, however, the HIA should contain an assessment of provision for “Youth” currently the HIA does not mention youth facilities or services.
Economy I agree with the assessment, however I’m concerned over the proposed location of the commercial allocation near to the Caxton Gibbet roundabout. The site appears to have no easy vehicular access from Cambourne West and doesn’t seem integrated as an employment area for the development. I would suggest consideration is given to relocating this area closer to the existing business park to create more of an employment hub.
Social and Cultural I agree with the assessment.
There are some domains missing from the assessment which need to be addressed, namely:
Open space/sport and opportunities for play The location of the sports area to the north of the site is not accessible easily from all parts of the development, there are also concerns that the physical shape of the allocated land may not lend itself to rectangular pitches.
What is the justification/need for the inclusion of an athletics track? These tracks tend not to attract a wide range users and may not be appropriate as the main sports facility, it may be an additional facility to cater for a minority of users but not the majority.
The central green space should not be counted as useable open space due to the location of the main road running through it – it becomes a transport corridor and not useable by children etc. due to safety concerns.
3.2 Risk assessment B 3.2.1 The nature of the potential health effects should be detailed.17 B Comments The HIA would have benefitted from the health impacts being presented in a table as well as the narrative in order for the positive and adverse effects to be easily identified
3.2.2 The findings of the assessment should be accompanied by a statement of the B level of certainty or uncertainty attached to the predictions of health effects. Comments Some level of uncertainty has been given but it not clear for each health determinant
3.2.3 The report should identify and justify the use of any standards and thresholds C used to assess the significance of health impacts. Comments Some have been given but it is not comprehensive e.g. the standards and thresholds used for Noise and Transport have not been given in the HIA although they maybe in the Environmental statement they are not referenced as such.
3.3 Analysis of distribution of effects C 3.3.1 The affected population should be explicitly identified. A Comments This is covered in section 5 for each topic
3.3.2 Inequalities in the distribution of predicted health impacts should be D investigated and the effects of these inequalities should be stated.18 Comments No inequalities have been given or identified, it is not clear if that is because there aren’t any or that it has not been assessed.
3.3.3 Effects on health should be examined based on the population profile.19 C Comments The assessment given in section 5 has not been linked to the profile given in section 3
4 Reporting B 4.1 Discussion of results C 4.1.1 The report should describe how the engagement undertaken has influenced B the HIA, in terms of results, conclusions or approach taken. Comments Partly addressed in section 4. The findings of section 4 with the exception of health care have not been addressed by the HIA
4.1.2 The report should state the effect on the health and wellbeing of the population D of the option and any alternatives that have been considered. Comments None Given
4.1.3 The report should justify any conclusions reached, particularly where some C evidence has been afforded greater weight than others. Comments The conclusions are partly justified in section 6.13
4.2 Recommendations B 4.2.1 There should be a list of recommendations to facilitate the management of A health effects and the enhancement of beneficial health effects.20
17 Does the assessment consider the severity of impact/exposure (intensity, reversibility and impact on vulnerable population groups), the impact magnitude (number of people affected and duration of impact/exposure) and the importance (political and ethical)? Have the health impacts of each alternative been assessed? Sometimes the health impacts are ranked and prioritised before making recommendations, if so; have the criteria for prioritising and ranking health impacts been given?
18 How does the report define inequalities? Inequalities are found between social groups and can be measured in different ways e.g. by geography, social class or social position, population (ethnicity, gender, sexuality etc).
19 It should be possible to determine whether effects are more prevalent in certain demographic or vulnerable groups. Comments Contained in section 7
4.2.2 The level of commitment of the project proponent to the recommendations and B mitigation methods should be stated. Comments Contained in section 7 – the Health Action Plan but some are recommendations rather than a firm commitment that they will be done as mitigation measures. If the evidence supports a need then they should be must do’s
4.2.3 There should be a plan for monitoring future health effects by relevant B indicators and a suggested process for evaluation. Comments Partly addressed in section 7
4.3 Communication and layout B 4.3.1 Information should be logically arranged in sections or chapters and whereabouts of important data should be signalled in a table of contents or A index. Comments The HIA is well laid out and in a logical order
4.3.2 There should be a lay summary (executive summary) of the main findings and conclusions of the study. Technical terms, lists of data and detailed D explanations of scientific reasoning should be avoided in this summary.21 Comments There is no executive summary
4.3.3 All evidence and data sources should be clearly referenced. A Comments The evidence is referenced at the end of the HIA
20 Do the recommendations cover the construction, operational and, where appropriate, decommissioning phases in the short, medium and long term (and are these timescales defined?). Some HIAs include recommendations as a management plan and list the roles and responsibilities of stakeholders and provide a timetable for action. Do the recommendations link with the findings of other relevant studies for example, Environmental Impact Assessment.
21 Does the summary cover all main issues discussed in the HIA report and contain at least a brief description of the project and the potentially affected population, a description of the most important positive and negative health effects and the project’s impact on equality, an account of the main recommendations and mitigation measures to be undertaken buy the developer and the main outline of the action plan recommended to manage, and monitor the health effects and evaluate the HIA. Is a brief explanation of the methods by which data were obtained, and an indication of the certainty which can be placed in them included? Cambourne West - Outline Planning Application (December 2014)
This response has been prepared using ‘The RECAP Waste Management Design Guide’. The RECAP Waste Management Design Guide (waste design guide) was adopted by Cambridgeshire County Council on 22 February 2012 as a Supplementary Planning Document (SPD) and forms part of the Cambridgeshire and Peterborough Minerals and Waste Local Development Framework (LDF).
The Guide puts significant emphasis on timely consultation with the Waste Collection and Disposal Authority. This forms the backbone of ensuring effective design for waste management. In most cases this should form part of a collaborative process.
The following documents have been reviewed and comments are outlined below:
Environmental Statement, December 2014 o Chapter 9 – Transport o Chapter 15 – Waste Effects
Please note: This response considers only occupation phase waste.
Environmental Statement
Chapter 9 – Transport Chapter 9 (para 9.161) states ‘the design of the roads serving the Site has been completed to ensure that access can be completed by large vehicles. Provision will be made within the completed Proposed Development to ensure that the suitable street widths serving development are provided in order to accommodate refuse collection vehicles’. As the application is submitted in outline, detailed layouts have not been prepared. Detailed swept path analysis of site layouts would be required at the Reserved Matters stage.
Full details of these requirements are contained in Chapter 7 of the guide, ‘Waste Collection’ and Appendix F, ‘Waste Collection Vehicle Tracking Path’. The developer must ensure that Highway Design allows for the use of waste collection vehicles in terms of their weight, length, width and height as specified, and this is especially crucial where block paviors are installed in domestic roads. Tracking requirements are within points 7.10 to 7.12 of the guide and the developer must ensure that the 5m minimum road width is provided, and that tracking evidence is provided to the council if this specification cannot be met at a specific location.
Routing requirements are at points 7.13-7.14, and the developer must ensure that routes allow vehicles to move mainly in a forward direction, and should not require vehicles to reverse more than 12m.
The developer also needs to consider the access arrangements for collections whilst the construction is in progress, as new residents gradually move in. The Executive Summary of the guide, point 6 applies in this case and that waste collection will not commence until road surfaces are complete to base layer, and access is not unreasonable, and not hindered by ongoing construction work. Until these criteria are met, provision will have to be made by the developer at their cost.
Chapter 15 – Waste Effects
Occupation phase waste Likely significant effects 15.95 - The 2010/2011 data presented in paragraphs 15.95 – 15.100 has been checked by the council and the figures quoted are accurate and modelling appears to be based on sound assumptions. The council can provide more up to date data for the year 2013-14 to assist the developer in their plans.
Mitigation 15.139 – the mitigation measures for occupation phase accord with the broad principles of the design guide. The council has taken this opportunity to signpost the developer to guidance included in the design guide that should be regarded as essential considerations and followed to mitigate the likely significant environmental effects of the proposed development.
The council would reinforce the importance of the following requirements: Internal storage - The council will require the developer to provide details of the specific products, and if required submit actual products, so that these can be assessed as to whether they fulfil the requirements of the guide and will provide a practical and useable method of separation of waste and recycling at the point of generation. This will also ensure that these are tailored to integrate with the councils bin provision and specific collection frequencies and arrangements. Waste Storage Containers – o The developer will be required to purchase all the domestic bins and caddy boxes as part of their planning obligation. This includes both for single houses and communal bin stores. This is an obligation detailed in the design guide toolkit, page 55, Basis for Conditions and Agreements, Waste Storage Containers and within chapter 4, paragraph 4.8 of the design guide. o Chapter 4, point 4.9 of the guide states that developers must ensure that external containers are in each property prior to occupation of a property, and prior to the commencement of a collection service, and the developer is aware of their obligation to do this as detailed in points 4.6.2-4.6.3 in the strategy. o Developers will be required to provide a secure compound for the storage of bins from a bulk delivery from the council, or the councils manufacturer, and if direct from the bin manufacturer, the developer will be required to provide a fork lift to unload these bins from the delivery lorry into the secure compound. o The responsibility for any lost, damaged or stolen bins whilst bins are stored by the developer, is with the developer and not the council. o The developer will be required to set up a process for the timely delivery of bins to a property as they become occupied, and ensure that clear and regular communication is made with the council to ensure properties are added onto collection rounds. The council will require the developer to submit a proposal for this process. o The developer must ensure that each property is registered with a Royal Mail postal address prior to commencement of any council provided collection service. Interim arrangements for waste collection prior to this are between the developer and the purchaser of the property. Waste Storage Points - The developer must ensure compliance with chapter 5, sections 5.6 and 5.7 of the guide that details the requirements for residential storage points, and the movement distances from the point of generation to the bin at 30m maximum, and from the bin to the collection point which is a 25m maximum, and these apply to both single houses and flats/apartments. Waste Storage for flats o For communal bin stores the council will assist the developer on the size and number of bins required for each bin store, as detailed in Table 4.1, page 21 of the guide, and above in ‘External Storage for flats’. This will ensure that the correct size bins are issued and ensure the split of bins for the segregation of waste are correct and adequate for the number of flats and residents who are allocated to use a specific store. o The installation of Waste Storage Compounds requires the developer to use and submit the Assessment Criteria Tool (Toolkit pages 50-54) and in this case the following are required by the council to be completed and submitted; Sheet A Waste Storage Compounds- residential.
Commercial Waste The mitigation measures highlighted in the ‘Waste effects’ chapter (15.153 -15.155) are in accordance with the design guide. The council would highlight the following key pieces of legislation that further affect commercial enterprises which would require further consideration: The Hazardous Waste Regulations 2005 make it a legal requirement to separate all hazardous wastes before collection for disposal. This includes fluorescent tubes, computer monitors and batteries. The Waste Electrical and Electronic Equipment (WEEE) Regulation 2006 makes the recycling and recovery of such waste types compulsory. The Landfill Directive makes the initial separation of waste types essential prior to landfilling.
The design and construction of commercial waste storage areas are identical to the requirements for flats and apartments. Chapter 6 in the guide, points 6.1-6.8 refer to the principles and specifications for above ground waste storage systems. With reference to point 6.8, the council will require that all waste storage compounds are covered. The council will require that all non-residential bin stores are constructed to the specifications as detailed in Appendix D ‘Design Specifications for Waste Storage Compounds’ and Appendix E ‘ Waste Storage Compound Security’. The council will be looking for evidence that these are complied with, both during consultation and in submitted drawings.
It is likely that storage/collection points for commercial waste will have some four wheeled containers so the movement distance of 10m from the collection point to the collection vehicle must be taken into account when planning for the position of these in relation to highway design and construction.
Bring Sites The number of properties planned for development is 2,350. The standard for the provision of bring sites is normally one for every 800 residential properties, (waste design guide 9.7-9.8). As the number of properties exceeds the requirement for a bring site the council will require the planning and provision of two bring sites in accordance with the Basis for Conditions and Agreements.
The developer needs to consider the design and location of a bring site with reference to the waste design guide 9.9-9.10. Innovative design and position should be explored to ensure the bring site is considered as part of the overall design of the development including the street scene.
The council will require the developer to install an underground bring site, which are less visually intrusive and these are detailed at points 9.11 and 9.12 in the waste design guide, with a typical specification for a site in Appendix G.
The council waste management officers welcome early consultation with the developer over the infrastructure, land, location, ownership and management of the bring site.
The installation of Bring Site Infrastructure requires the developer to complete and submit the Assessment Criteria Tool (Toolkit pages 50-54) and in this case the following are required by the council to be completed and submitted for the Bring Site;
Sheet B Provision of Bring Site Infrastructure- Phase 1 Bring Site
The bring site is a financial obligation on the developer specified in chapter 9 of the design guide and the toolkit, Basis for Conditions and Agreements pages 55-56, ‘Bring Sites’
Temporary Recycling Facilities
In accordance with the standards for the provision of Bring Sites for new residential developments, (design guide page 41), and point 9.11 of the guide, ‘Management and Maintenance’, the council will also require the developer to set up and manage at the developers cost, a temporary bring site recycling facility during the construction phase, to be in place on occupation of the 50th residential property, until the HRC is operational.
The council will require details of the proposed location, size, and access to this site, and consultation over the number of banks and materials to be offered for new residents to recycle. The council will work with the developer to establish this facility and may be able to organize and provide the required recycling bins and banks, which will be charged to the developer.
The RECAP Waste Management Design Guide Toolkit The design guide contains a Toolkit in Section 10. This Toolkit is a practical element of the Guide and will allow the developer, in consultation with the Local Planning Authority, to make an effective assessment of the waste management requirements placed upon them and demonstrates compliance as necessary.
The council will require the developer to complete and submit all sections of the Toolkit: Design Standards Checklist (Step 1 and Step 2) – this should be submitted with all initial design proposals and will be reviewed by the Local Planning Authority. The ‘Checklist’ will then be submitted with all final development applications following discussion and amended where necessary. Assessment Criteria – A Simple Assessments as detailed in point 10.15 of the design guide need to be completed and submitted, for; o Sheet A for Waste Storage Compounds Residential o Sheet A for Waste Storage Compounds Non-Residential Sheet B for Provision of Bring Site Infrastructure Basis for Condition and/or Agreement
The council seeks early discussion with the developer in relation to designing for effective waste management.
Kylie Laws – Waste Recycling and Minimisation Officer [email protected] 01954 713192
Cambridgeshire Local Access Forum
Chairman: Mary Sanders Secretary: Mrs Gail Stoehr 30 West Drive Highfields Caldecote Cambridge CB23 7NY Tel: 01954 210241 Fax: 0870 7052759 Email: [email protected]
Ed Durrant South Cambridgeshire District Council South Cambridgeshire Hall Cambourne Business Park Cambourne Cambridge CB23 6EA
By email only
19th February 2015
Dear Mr Durrant RE: S/2903/14/OL Land to the West of Cambourne (Excluding Swansley Wood Farm) This submission constitutes formal advice from the Cambridgeshire Local Access Forum. South Cambridgeshire District Council is required, in accordance with section 94(5) of the Countryside and Rights of Way Act 2000, to have regard to relevant advice from this forum in carrying out its functions.
The Cambourne Bridleway needs to be extended around this new development and be part of the planning approval. The bridleway is a fantastic, well used facility for all users. The Cambs LAF considers this to be a great example of innovative planning practice.
LAF would be grateful to be kept informed of how its advice has been received and considered.
Mrs Gail Stoehr Secretary
Cambridgeshire Local Access Forum was set up by Cambridgeshire County Council as required by the Countryside and Rights of Way Act 2000, and its remit is to advise relevant bodies as defined in Section 94(4) of the Countryside and Rights of Way Act 2000 on matters relating to access to the countryside. Section 94(4) bodies are required by the legislation to take the views of the Local Access Forum into account, and the latest Guidance issued by The Secretary of State at the Department for Environment, Food and Rural Affairs lists the South Cambridgeshire District Council as a Section 94(4) body. National Planning Casework Unit 29/02/2015 From: Tab Omar [mailto:[email protected]] Sent: 29 January 2015 16:09 To: Phillips Andrew Subject: Environmental Statement - "Land to the West of Cambourne" - S/2903/14/OL
Dear Mr Phillips
I acknowledge receipt of your council’s letter, dated 15th January, 2015.
We have no comments to make on this application.
Regards
Tab Omar National Planning Casework Unit Department for Communities and Local Government 5 St Philips Place Colmore Row Birmingham B3 2PW
Date: 17 February 2015 Our ref: 142036 Your ref: S/2903/14/OL
Mr Edward Durrant Customer Services Planning and New Communities Hornbeam House South Cambridgeshire District Council Crewe Business Park [email protected] Electra Way Crewe Cheshire CW1 6GJ BY EMAIL ONLY T 0300 060 3900
Dear Edward
Planning consultation: Development of up to 2,350 residential units including affordable housing; retail, use classes A1-A5 (up to 1.04 ha); offices/light industry, use class B1 (up to 5.66ha); community and leisure facilities, use class D1 and D2 (up to 0.92 ha); Two primary schools and one secondary school (up to 11.28 ha), use class D1; three vehicular access points including the extension and modification of Sheepfold Lane, a four arm roundabout provided on A1198/Caxton Bypass and an access point off the A1198, south of the Caxton Gibbet to serve the proposed employment uses; a network of segregated pedestrian and cycle routes; sustainable drainage system and other infrastructure; together with associated earth works, parking, open space, including equipped play, playing fields and landscaping. Location: Land to the West of Cambourne (Excluding Swansley Wood Farm)
Thank you for your consultation on the above which was received on 13 January 2015. Natural England is a non-departmental public body. Our statutory purpose is to ensure that the natural environment is conserved, enhanced, and managed for the benefit of present and future generations, thereby contributing to sustainable development.
We note that the Local Plan for Cambourne West proposes 1,200 dwellings on 49.3ha of land to the west of Cambourne and that this application is an extension of that proposal, covering 147.56ha and reaching the A1198 and A428 boundaries.
WILDLIFE AND COUNTRYSIDE ACT 1981 (As amended) CONSERVATION OF HABITATS AND SPECIES REGULATIONS 2010 (As amended)
No objection – no conditions requested This application is in close proximity to Elsworth Wood Site of Special Scientific Interest (SSSI). It is also approximately 8km from a European site, Eversden and Wimpole Woods Special Area of Conservation (SAC). However Natural England is satisfied that the proposed development being carried out in strict accordance with the details of the application, as submitted, will not damage or destroy the interest features for which these sites have been notified. We therefore advise your authority that these sites do not represent a constraint in determining this application. Should the details of this application change, Natural England draws your attention to Section 28(I) of the Wildlife and Countryside Act 1981 (as amended), requiring your authority to re-consult Natural England.
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Soils and Land Quality Having considered the proposals as a consultation under the Development Management Procedure Order (as amended), and in the context of Government's policy for the protection of the ‘best and most versatile’ (BMV) agricultural land as set out in paragraph 112 of the National Planning Policy Framework, Natural England draws your Authority’s attention to the following land quality and soil considerations:
1. The information provided with the planning application does not appear to include any assessment of the impact on agricultural land.
2. However survey information held by Natural England indicates the site to be a mix of Grade 2 and 3a agricultural land, i.e. that all of the farmland within the application appears to fall within the category of ‘best and most versatile’ agricultural land (Grades 1, 2 and 3a land in the Agricultural Land Classification (ALC) system). This information can be supplied on request.
3. The site area is given as 147.56ha although 49ha would be maintained as landscaped public open space. We therefore estimate that 98ha of ‘best and most versatile’ agricultural land would be irreversibly lost, the majority of which is Grades 3a in the ALC system.
4. Government policy is set out in Paragraph 112 of the National Planning Policy Framework which states that:
‘Local planning authorities should take into account the economic and other benefits of the best and most versatile agricultural land. Where significant development of agricultural land is demonstrated to be necessary, local planning authorities should seek to use areas of poorer quality land in preference to that of a higher quality.’
5. It is recognised that a proportion of the agricultural land affected by the development will remain undeveloped (for example as habitat creation, landscaping, allotments and public open space etc). In order to retain the long term potential of this land and to safeguard soil resources as part of the overall sustainability of the whole development, it is important that the soil is able to retain as many of its many important functions and services (ecosystem services) as possible through careful soil management.
6. Consequently, we advise that if the development proceeds, the developer uses an appropriately experienced soil specialist to advise on, and supervise, soil handling, including identifying when soils are dry enough to be handled and how to make the best use of the different soils on site. Detailed guidance is available in Defra Construction Code of Practice for the Sustainable Use of Soils on Construction Sites (including accompanying Toolbox Talks) and we recommend that this is followed.
Protected Species We have not assessed this application and associated documents for impacts on protected species.
Natural England has published Standing Advice on protected species. The Standing Advice includes a habitat decision tree which provides advice to planners on deciding if there is a ‘reasonable likelihood’ of protected species being present. It also provides detailed advice on the protected species most often affected by development, including flow charts for individual species to enable an assessment to be made of a protected species survey and mitigation strategy.
You should apply our Standing Advice to this application as it is a material consideration in the determination of applications in the same way as any individual response received from Natural England following consultation.
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The Standing Advice should not be treated as giving any indication or providing any assurance in respect of European Protected Species (EPS) that the proposed development is unlikely to affect the EPS present on the site; nor should it be interpreted as meaning that Natural England has reached any views as to whether a licence may be granted.
If you have any specific questions on aspects that are not covered by our Standing Advice for European Protected Species or have difficulty in applying it to this application please contact us at with details at [email protected].
Green Infrastructure Whilst we welcome the submitted Landscape and Ecology Plan, which appears to show an appropriate mix of features to support both residents and wildlife, at this stage the submission lacks detail on the various components. We therefore advise your authority to secure the production of a GI Statement by planning condition, as at this stage it is likely that the project is not sufficiently detailed to provide all the information required. We recommend that you review Natural England’s GI Guidance which can be found on the Natural England GI publications pages where you will also find several useful case studies and examples of good practice for a range of development types.
Other advice We would expect the Local Planning Authority (LPA) to assess and consider the other possible impacts resulting from this proposal on the following when determining this application:
local sites (biodiversity and geodiversity) local landscape character local or national biodiversity priority habitats and species.
Natural England does not hold locally specific information relating to the above. These remain material considerations in the determination of this planning application and we recommend that you seek further information from the appropriate bodies (which may include the local records centre, your local wildlife trust, local geoconservation group or other recording society and a local landscape characterisation document) in order to ensure the LPA has sufficient information to fully understand the impact of the proposal before it determines the application. A more comprehensive list of local groups can be found at Wildlife and Countryside link.
Biodiversity enhancements This application may provide opportunities to incorporate features into the design which are beneficial to wildlife, such as the incorporation of roosting opportunities for bats or the installation of bird nest boxes. The authority should consider securing measures to enhance the biodiversity of the site from the applicant, if it is minded to grant permission for this application. This is in accordance with Paragraph 118 of the NPPF. Additionally, we would draw your attention to Section 40 of the Natural Environment and Rural Communities Act (2006) which states that ‘Every public authority must, in exercising its functions, have regard, so far as is consistent with the proper exercise of those functions, to the purpose of conserving biodiversity’. Section 40(3) of the same Act also states that ‘conserving biodiversity includes, in relation to a living organism or type of habitat, restoring or enhancing a population or habitat’.
We would be happy to comment further should the need arise but if in the meantime you have any queries please do not hesitate to contact us.
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For any queries relating to the specific advice in this letter only please contact me on 0300 060 1232 or [email protected]. For any new consultations, or to provide further information on this consultation please send your correspondences to [email protected].
We really value your feedback to help us improve the service we offer. We have attached a feedback form to this letter and welcome any comments you might have about our service.
Yours sincerely
Francesca Shapland Planning and Conservation Adviser
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Victoria House Our ref: IB/Cambourne West Capital Park Cambridge CB21 5XB 26 February 2015 Tel: 01223 597710 Mob: 07785 393853 Ed Durrant Email: [email protected] Senior Planning Officer www.property.nhs.uk South Cambridgeshire District Council South Cambridgeshire Hall Cambourne Business Park Cambourne CB23 6EA
Dear Ed
Response to Planning Application S/2903/14/OL Land to the West of Cambourne (Excluding Swansley Wood Farm)
I am pleased to provide a response to the above planning application
NHS Property Services Ltd manages former PCT Estate and provides Strategic Estates advice, including advice on Land Planning issues, to the two main NHS commissioning bodies, NHS England who commission Primary Care Services and Cambridgeshire and Peterborough Clinical Commissioning Group, who commission the bulk of other NHS services in the area. This response is therefore provided by NHS Property Services on behalf of NHS England (East Anglia Area Team) and Cambridgeshire and Peterborough CCG.
In summary; we confirm that the assertions made in the application about expansion of the Health facility at Sackville House being the NHS commissioners preferred option for providing additional capacity is correct. the capacity data in the HIA is incorrect and has ignored the restrictions arising from Practice boundaries and the constraints of the existing infrastructure. the proposed development will have major, not moderate impact on Health services. we request a maximum S106 contribution of £1,492,250 to Health to mitigate the impact of the development.
Background Community based Health services to Cambourne are mainly provided at Sackville House, Cambourne. The facility opened in November 2004 and was originally designed to provide Primary and Community medical services for a population of around 8000 arising from the planned 3300 homes.
NHS Property Services Limited, Registered in England & Wales No: 07888110
The approval of a further 950 homes along with a higher than expected population, averaging 2.74 per household, and one of the highest birth rates in the world has led to significant pressure on the Health services at Sackville House.
An extension was planned in 2008 to provide the capacity needed for the additional 950 homes but following other space within Sackville House being released, additional capacity has been created by internal re-organisation and re-configuration, which has just been completed. This leaves the potential of a future extension as the main option for providing future physical capacity for Health services in Cambourne.
Impact of the development We have reviewed the Design and Access Statement and the Health Impact Assessment. Whilst the approach suggested for mitigating impact of the development on Health services and infrastructure does reflect the discussions NHS Property Services, on behalf of NHS England and Cambridgeshire & Peterborough CCG, has had with the Developer’s consultants there are some significant errors in their assessment of capacity. This in turn, in our view, means that their assessment that the development will have moderate impact on Health services is incorrect and should be adjusted to Major impact.
Current Patient Capacity Chapter 16 of the Environmental Impact Statement and the complete Health Impact Statement, Appendix 16.1 sets out in Table 16.3 an assessment of GP capacity. The data is incorrect for the following reasons; patient number are out of date and significantly understated The number of GPs is significantly overstated as they include GP Registrars ( Trainees) and have used actual number, not whole time equivalents which takes account of Part time staff. It takes no account of Practice boundaries. GPs only accept patients from within their agreed Practice boundary. In the first table, neither Papworth Everard or Bourn accept patients from Cambourne and none of the Practices in the second table accept Cambourne patients The only Practice that currently accepts Cambourne residents is Monkfield Medical Practice based at Sackville House The HIA assessment takes no account of building capacity
We have revised the figures in the table below;
Practice Approximat Number of Numbers as Number WTE Patients Spare Name e Distance Registered at 1 March of GPs GPs per GP Capacity* from Patients 2015 Proposed Developmen t# (km) < 5 km from Proposed Development Monkfield 1.9 9,013 9920 5 3.5 1,802 2834 -13 -3620 Medical Practice
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Papworth 3.6 6,211 6719 6 3.75 1,035 1791 4,589 31 Surgery The Surgery 4.0 5,909 5942* 3 3 1,969 1980 -509 -542 Bourn *As at Oct 2014
The Practices in the table which are>5km from the proposed development should be discounted as they are too far from Cambourne and also do not include Cambourne in their Practice boundaries.
Recalculating the “total remaining capacity” of the 3 nearest Practices shows that there is currently a shortfall of 4131, 10866 lower than the 6735 suggested by the Developer.
It should also be noted that the measure of 1800 patients per GP is a very crude, historic, measure that does not take account of actual workload, dependent on demography and epidemiology of the patient list and of other staff, such as Nurse Practitioners, delivering services that in the past would have been delivered by GPs. Neither does it account for the plurality of service models used for delivery of Primary Medical Services.
The Monkfield Medical Practice would assert that that their current workload is significantly impacted by the birth rate and number of young families in Cambourne. The current weighting used to assess need does not weight this factor particularly highly which means we only have the anecdotal evidence for this assumption rather than formal qualitative and quantative data.
Current Physical Capacity The HIA has not assessed Physical capacity. For the reasons set out above, we should ignore the Bourn and Papworth Surgeries, whose buildings are significantly undersized for their current patient list size, and only consider Sackville House.
The current net internal area for Health services, excluding the office accommodation element in former Trading standards office, is 952 sm. This includes space used for services such as Physiotherapy and Minor Surgery that are provided for the wider area. This space could be converted into further consulting space for the GP Practice but as the Cambourne population grows there will actually be an increased requirement for the facility to operate as a hub, providing a wider range of Health services to Cambourne and the surrounding villages.
A Capacity study was undertaken by NHS England in 2013 that showed the average physical capacity for GP premises in East Anglia at that time was 16.64 patients per square metre. The study pointed out that this is likely to be higher than the optimal figure as many of the properties are undersized and have smaller room sizes than are currently required under present NHS standard. It does give an indication of capacity. The table below uses that figure to calculate the physical capacity at Sackville House. Changes to opening hours and other aspects of service delivery may impact on capacity. It also does not take account of the design of the building and whether the flow of patients and staff would be operationally feasible with the maximum number of patients suggested. For new, purpose-built health premises, the average figure of patients per sm is much lower due to increased room sizes, a wider range of spaces required and the far wider range of
NHS Property Services Limited, Registered in England & Wales No: 07888110
services that now need to be delivered in a Community Health facility that would in the past would have dealt with in an acute hospital setting. Current NHS strategy is for more service to be delivered in community settings in the future.
Net Average Space space Current Patients for non for Homes List m2 per sm GMS GMS Capacity Spare 3700 approx 9920 952 16.64 88.5 863.5 14368.64 4448.64 4250 11500 952 16.64 88.5 863.5 14368.64 2868.64 6600 18000 952 16.64 88.5 863.5 14368.64 -3631.36
The table shows that the building does now have the physical capacity to serve the population of the total 4250 homes already being built. It indicates that at that point it would have capacity for a further 2868 patients. We would suggest caution with that figure for the reasons given above. The final line shows that once the additional 2350 homes are built, making 6600 in total, there would be a shortfall in capacity of 3631 patients.
Options for future Health capacity The figures above demonstrate that there will be a need for increased infrastructure for Health. The HIA indicates that the NHS has indicated that the preferred solution is to provide services to the residents of the new homes by expanding Sackville House rather than building a second Health facility in Cambourne.
The Cambridgeshire and Peterborough health system was shown in 2014 to be one of the 11th most financially challenged systems in England. NHS England, nationally and locally, has made it clear that to make Primary Care services more sustainable and maintain quality, larger list sizes operating out of one building are required, together with some of the larger sites acting as hubs that offer a wider range of Health and Social Care, shifting care closer to where people live.
A second surgery at Cambourne would require additional start up funding and require a minimum level of staffing that would exacerbate the clinical recruitment problems.
Keeping to the one site means that, whilst acknowledging the current recruitment problems, the Practice can grow organically as the population increases and that further physical space would not be required immediately.
Based on the housing trajectory set out in the application and the capacity set out above, our initial estimate is that funding would need to be made available on completion of 800 dwellings with the expansion in place by the 1000th dwelling.
The size of the extension would be determined by the range of services that need to be located in the building, alongside the normal range of GP services.
NHS Property Services Limited, Registered in England & Wales No: 07888110
In 2008, an extension of 466 sm was proposed. Due to the design of the building and the loss of some rooms in order to facilitate the extension, it would have only delivered an additional 231 sm of clinical space. A new feasibility exercise would be required to consider options for the building and a design that will provide the accommodation needed in the short term with flexibility for future adaptation, making it responsive to changes in services requirements and models of service delivery.
Proposed S106 contribution for Health We acknowledge that there is currently a balance of the S106 contribution from the earlier 950 application that was originally intended to fund an extension at Sackville House. Negotiations are ongoing to decide how much of that contribution can be justifiably used to pay for the space that Health has now taken in the former Trading Standards office. Once this is concluded and agreed, we anticipate that there may be a sum remaining and discussions will be needed with the Local Planning Authority, Developers and Parish Council as to how this could be used.
Within South Cambridgeshire we have agreed contributions on some applications at a rate of £635 per dwelling, index-linked. For Cambourne West, this would result in a contribution to Health of £1,492,250. Until such time as we have a feasible, costed design, we cannot confirm that this is the right amount to provide a built extension.
In addition to feasibility studies being required for the extension options, NHS England will also need to approve a full business case for the final preferred option.
We therefore suggest that this figure be considered as the maximum contribution, but the actual contribution be the lower of this figure and the actual costs.
Please do get in touch if you need to discuss this proposal or need any further information.
Yours sincerely
Ian Burns Area Strategic Estates Planner Eastern England
NHS Property Services Limited, Registered in England & Wales No: 07888110 Police Architectural Liaison Officer 10/02/2015
Your reference: S/2903/14/OL Our reference: ALO/21/15/TH
Dear Mr Durrant,
Thank you for sending me information regarding the land to the west of Cambourne. I have read through the documentation I have picked out the below points from the DAS regarding the principles of designing out crime:
DAS Page 11 – External lighting should be kept to a minimum required for public safety and security and there should be no unacceptable adverse impact. Of relevance is that lighting must be adequate for public safety and security. DAS Page 67 – Structure. Public Open Spaces, e.g. roads, greenways etc will have buildings fronting (wherever possible). Natural surveillance is the key element here DAS Page 77 – SAFER PLACES: Key principles outlined e.g. access and movement and surveillance etc. Also mentioned is crime impact assessment. DAS Page 111 – Car parking. Also designed not to dominate the street. Underground/undercroft mentioned. No underground exists in Cambourne at the moment. DAS Page 113 – Public Spaces well managed and safe.
Whilst the application is for layout overall and is outline and is too early for me to comment, below is a standard extract from other submissions made by us in the past and has been used where we have been asked to comment on EIA, the comments being relevant at all stages of an application.
As discussed many times crime has been shown to have a carbon cost and therefore could be considered as an environmental issue. This is especially relevant where crime prevention has not been incorporated into the design process and not been evidenced as a design constraint.
As with any major development crime prevention / community safety should instruct and form part of the ethos to the design process so it may be more appropriate that, rather than inclusion of crime prevention / community safety within an environmental impact assessment, it would be more beneficial for the scheme to have appropriate around the table discussions at an early design stage prior to the submission of any planning application. To that end the Crime Prevention Design Team would welcome the opportunity to assist in giving appropriate and commensurate crime prevention advice relevant to the proposals under discussion. This could then be evidenced within a planning statement/Design & Access Statement submitted at Full planning application or Reserved matters application stages as detailed below.
One of the key elements of NPPF is “to ensure that developments: create safe and accessible environments where crime and disorder, and fear of crime, do not undermine quality of life or community cohesion;”. In order to facilitate this legislation this office would request planning permission only be granted, if, in the Design and Access Statement’s for each element of the development the developers demonstrate how they have addressed the following design, layout and specification issues that impact on the safety, security sustainability and community cohesion; Ensure footways, frontages, bus stops, publicly accessible spaces, open space or transport interchanges are overlooked, The development is designed with consideration to management and maintenance – to discourage crime now or in the future, The development has well defined routes, spaces and entrances that provide a convenient circulation without compromising security and safety, The development is structured so different uses do not conflict, The development is designed to promote a sense of ownership, respect, territorial responsibility and community, That all elements of the development include well designed security features, The development generates a level of human activity that is appropriate to the location and creates a reduced risk of crime and a sense of safety at all times. In addressing the criteria outlined the applicant/s would be expected to adopt, where appropriate, the principles and practices of the Secured by Design Award Scheme.
In conclusion we would not require crime prevention to be a part of the environmental assessment for this development but would ask for consultations prior to submission of planning application/s so that crime and fear of crime can be reduced or eliminated, as far as possible, from this development and appropriate information submitted within Design and Access Statements.
Ted Hawkins, Architectural Liaison Officer Cambridgeshire Constabulary Crime Prevention Design Team (Estates) Headquarters HINCHINGBROOKE PARK HUNTINGDON PE29 6NP
Creating a sporting habit for life
Mr E Durrant South Cambridgeshire District Council South Cambridgeshire Hall Cambourne Cambridge CB23 6EA
3 February 2015
Our Ref: E/SC/2015/38628/N
Dear Mr Durrant,
Application S/2903/14/OL Reference: Site Address: Land to the West of Cambourne, CambS CB23 3PH Proposal: Development of up to 2,350 residential units including affordable housing; retail, use classes A1-A5 (up to 1.04 ha); offices/light industry, use class B1 (up to 5.66ha); community and leisure facilities, use class D1 and D2 (up to 0.92 ha); Two primary schools and one secondary school (up to 11.28 ha) etc,
Thank you for consulting Sport England on the above application.
The site is not considered to form part of, or constitute a playing field as defined The Town and Country Planning (Development Management Procedure) (England) Order 2010 (Statutory Instrument 2010 No.2184), therefore Sport England has considered this a non-statutory consultation.
However, the DCLG Planning Practice Guidance for Open Space, Sports and Recreation Facilities (March 2014) states that Sport England should be consulted on a wide range of applications on a non-statutory basis including residential developments of 300 dwellings or more; the creation of major new sports facilities (including new playing fields) or the loss of major sports facilities.
It is understood that the application proposes a major extension to the new settlement of Cambourne, with up to 2,350 new homes, a new secondary school, two new primary schools and proposed public open space including provision for outdoor sport.
Sport England has assessed the application against its adopted planning policy objectives. The focus of these objectives is that a planned approach to the provision
Sport England, SportPark, 3 Oakwood Drive, Loughborough, Leicestershire, LE11 3QF, T: 020 7273 1777 E: [email protected] - www.sportengland.org
Creating a sporting habit for life
of facilities and opportunities for sport is necessary in order to meet the needs of local communities. The occupiers of any new development, especially residential, will generate demand for sporting provision. The existing provision within an area may not be able to accommodate this increased demand without exacerbating existing and/or predicted future deficiencies. Therefore, Sport England considers that new developments should be required to contribute towards meeting the demand they generate through the provision of on-site facilities and/or providing additional capacity off-site (Planning Policy Objective 3). The level and nature of any provision should be informed by a robust evidence base such as an up to date Sports Facility Strategy, Playing Pitch Strategy or other relevant needs assessment.
We understand that South Cambs DC/Cambridge City Council are currently undertaking a Playing Pitch Strategy to cover the two local authority areas, therefore it is essential the outputs from this project feed into the planning process for this phase of the Cambourne development.
Outdoor Sport
The population to be generated by the proposed development is calculated at 6,345. This additional population will generate a policy requirement for 10.15 hectares for outdoor sport, and it is calculated that the proposal will provide 10.2 hectares for outdoor sport, thus broadly meeting this policy requirement.
However, Sport England does have some concerns regarding the detailed proposals put forward for outdoor sport:
Sport England does not advocate the provision of grass athletics tracks for community use. Such facilities are often provided on school sites for curriculum use, but community facilities for athletics are normally provided via an all-weather track which is suitable for club use and contains facilities for field events as well as suitable ancillary facilities. It is therefore unclear what the driver is for the provision of this facility as part of the West Cambourne proposals. The main playing pitches will be provided on the land to the north of the proposed athletics track, though the irregular shape of this site does not make it ideal for the siting of pitches. It would be helpful to see a more detailed layout plan for this land to ascertain the number, size and type of pitches to be provided. The second area for formal sport, adjacent to western primary school, appears to be much smaller and suitable only for small-sided football or rugby. If this is the case it might not be essential to provide changing facilities as mini/junior soccer players do not normally use changing facilities. However, it would be easier to comment further on this element if more detailed plans are available for this site. There appears to be a lack of facilities for informal sport (e.g. multi-use games areas) or other facilities such as tennis courts, bowling greens etc.
Sport England, SportPark, 3 Oakwood Drive, Loughborough, Leicestershire, LE11 3QF, T: 020 7273 1777 E: [email protected] - www.sportengland.org
Creating a sporting habit for life
All new areas of sports pitches and ancillary changing facilities/pavilions must meet Sport England technical standards contained within our documents ‘Natural Turf for Sport’ and ‘Pavilions and Clubhouses’. These documents can be downloaded from the Sport England website here: http://www.sportengland.org/facilities-planning/tools-guidance/design-and- cost-guidance/
I have consulted National Governing Bodies for Sport (NGBs) with regard to the proposals and have received the following responses at the time of writing:
FA (Football) – no comments received
England Hockey - The allocation of land for sporting development seems fine and sufficient for growth.
There is no provision for hockey in Cambourne and it is difficult to predict that formal clubs would emerge from the area, the two neighbouring towns of St Ives and St Neots currently take players from Cambourne.
Without the provision of an AGP this would remain the case. Whilst an AGP would create the opportunity for further player growth, it is not an area of high strategic importance to EH.
LTA (Tennis) - Will the new schools have tennis provision on their sites? In the community facilities it doesn’t mention park Tennis Courts obviously we would like to see at least one park with some tennis courts.
In Cambourne we have one club who have recently expanded number of courts to five. It would be good if they could be consulted as to future requirements.
Please see the link for the club information http://cambournetennis.clubbuzz.co.uk/
ECB (Cricket) – no comments received.
RFU (Rugby Union) – no comments received.
Any comments received following the submission of these representations will be forwarded to the case officer.
Sport England, SportPark, 3 Oakwood Drive, Loughborough, Leicestershire, LE11 3QF, T: 020 7273 1777 E: [email protected] - www.sportengland.org
Creating a sporting habit for life
Indoor Sport
The proposals do not include any provision for large scale indoor community sports facilities such as sports halls and swimming pools.
Any facilities of this type need to be considered with regard to existing and/or proposed facilities within existing areas of Cambourne, as these types of facility will typically serve the whole of the Cambourne area, taking into account sports facilities already provided at the leisure centre and existing secondary school.
The main opportunity for indoor sports provision to serve the wider community would be via the proposed additional secondary school. This is shown as being sited adjacent to the existing secondary school, which opened in September 2013. There is therefore the opportunity to co-ordinate facility provision and programming to ensure that complimentary facilities are provided to serve both school and local community.
You may be aware that Sport England’s Sports Facilities Calculator (SFC) can help to provide an indication of the likely demand that will be generated by a development for certain facility types. The SFC indicates that a population of 6,345 will generate demand for: 1.74 sports hall courts, 1.26 swimming lanes, 0.19 AGPs and 0.42 indoor bowling rinks.
When combined to reflect the total of 6,600 residential units in Cambourne (approx. population 16,500) the demand generated for sports facilities equates to:
FACILITY TYPE DEMAND Sports Hall 4.53 courts (or 1.13 sports halls) Swimming Pool 3.28 lanes (or 0.82 of a 4-lane pool) Indoor Bowls 1.13 rinks Artificial Grass Pitches 0.48 pitch (full-size) . Given existing facility provision in Cambourne it is unlikely that there is a strong case for additional indoor or AGP provision in the village based on the projected overall population. However, it is likely that there will still be an opportunity to open up the new facilities at the proposed secondary school to supplement the existing provision within Cambourne. Consideration should be given to securing S106 or CIL contributions towards indoor or outdoor sports facility provision required as a result of this development.
Sport England is therefore supportive in principle of the proposals with regard to provision for indoor/outdoor sport., but would request that further consideration is given to the issues outlined in the above representations, and an overall strategy for the development and implementation of sports facilities in Cambourne is developed to ensure a co-ordinated and planned approach to facility development is delivered.
Sport England, SportPark, 3 Oakwood Drive, Loughborough, Leicestershire, LE11 3QF, T: 020 7273 1777 E: [email protected] - www.sportengland.org
Creating a sporting habit for life
Any planning permission granted should be subject to the following conditions to ensure the new playing fields are constructed to a suitable standard and protected from inappropriate development:
1. No development shall take place unless and until: a) A detailed assessment of ground conditions of the land proposed for the new fields as shown on submitted plans shall be undertaken (including drainage and topography) to identify constraints which could affect playing field quality; and b) Based on the results of this assessment to be carried out pursuant to (a) above of this condition, a detailed scheme to ensure that the playing fields will be provided to an acceptable quality (including appropriate drainage where necessary) shall be submitted to and approved in writing by the Local Planning Authority after consultation with Sport England.
The works shall be carried out in accordance with the approved scheme within a timescale to be first approved in writing by the Local Planning Authority after consultation with Sport England.
Reason: To ensure that site surveys are undertaken for new or replacement playing fields and that any ground condition constraints can be and are mitigated to ensure provision of an adequate quality playing field and to accord with LP Policy **
2. The playing field/artificial grass pitch shall be used for Outdoor Sport and for no other purpose (including without limitation any other purpose in Class D2 Use Classes Order 2005, or in any provision equivalent to that Class in any statutory instrument revoking and re-enacting that Order with or without modification).
Reason: To protect the playing fields from loss and/or damage, to maintain the quality of and secure the safe use of sports pitch/es and to accord with LP Policy **. :
The comments made in response to this application, do not in any way commit Sport England’s or any National Governing Body of Sport’s support for any related application for grants funding.
Thank you once again for consulting Sport England. We would be grateful if you would advise us of the outcome of the application by forwarding a copy of the decision notice.
Sport England, SportPark, 3 Oakwood Drive, Loughborough, Leicestershire, LE11 3QF, T: 020 7273 1777 E: [email protected] - www.sportengland.org
Creating a sporting habit for life
Please contact me on the number shown below should you wish to discuss the contents of this letter in more detail.
Yours sincerely,
Philip Raiswell Planning Manager
Sport England, SportPark, 3 Oakwood Drive, Loughborough, Leicestershire, LE11 3QF, T: 020 7273 1777 E: [email protected] - www.sportengland.org These comments are on behalf of Sustrans, the charity working to enable people to choose to travel sustainably for their everyday journeys.
Cambourne is recognised by its residents and by professionals as being disappointingly car- dependent (see inter alia Lessons from Cambourne, 2007). This is attributed to the lack of safe cycle routes to its surrounding villages and countryside. In our opinion it is also caused by the rather fragmentary layout of its existing internal cycle routes, which are generally two-way footways on one side of some roads, shared with pedestrians. These don’t link homes legibly either to the High Street with its shops and community facilities, or to the Business Park, which itself is segregated from the three villages of Cambourne and linked well only with the external high-speed road network. The transition from streets which might be considered safe for cycling to those which are not, and the links onto the existing shared-use footways are not always evident on the ground, nor the links always convenient to ride.
We believe that the West Cambourne proposals could do a lot to enable its residents to choose to walk and cycle for most of their daily journeys, and that it must be required to do so. In achieving this it must also contribute to improving walking and cycling access for all Cambourne’s residents, within the whole settlement and with its surrounding villages.
We welcome the developer’s overall transport objectives, expressed in para 9.156 of the Environmental Statement, and table 9.19 which lists measures to be taken to enable walking and cycling to play a daily role in the lives of future residents. We welcome also the map on page 25 of the Design and Access Statement, outlining a 5 km cycling catchment which includes the villages of Hilton, Great Gransden and Hardwick. Given high quality rural cycling routes most people will indeed happily cycle much further than this, and should be enabled to do so. We welcome also the mapping (in the Parameters Plan) of footpaths and cycleways whose orientation is generally towards the existing settlements of Cambourne, and its town centre. It is evident that, providing such routes are effectively and directly linked through to the existing town centre, as well as to the employment area in the north of the proposed site, and to the Business Park, they can provide a shorter walking or cycling journey than would the roads. This is excellent.
However, we are unsure whether providing a principal network for walking and cycling between, and not through, the various blocks of residential development is the best way to enable high levels of active daily travel. It risks having the effect of the network remaining unseen, being used perhaps in the daytime only, and considered unsafe after dark, because lacking passive surveillance from the surrounding areas of settlement.
We would suggest, rather, that these principal walking and cycling routes, giving direct access to people’s main daily destinations, should pass through quiet streets in the body of each block of housing and given priority over the slow-moving motor traffic in these streets. The greenways separating the parcels of housing might then remain as linear parks and nature reserves whose main function is for walking, jogging and (given sealed surfaces) for weekend cycling.
We find little information in the planning application relating to any principles of street or housing design, and feel that consent should be withheld until a simple design code, aimed at thoroughly achieving sustainability in transport and other terms, is provided. It might state, for example, that all streets except for the spine road should be designed to limit speed to less than 20 mph, so that they can be cycled in safety by all but the youngest. We believe such street design is essential. Cycle routes linking directly to principal destinations such as places of study and employment and the town centre need to be given priority at all crossings except perhaps of the spine road, and made much more direct than motor vehicle routes to the same destinations. This can be achieved by applying filtered permeability principles such as the point-closure to motor traffic of roads which are otherwise visual thoroughfares on walking and cycling desire lines.
The design code needs to specify cycle parking for residents located adjacent to the front door, thus making cycling journeys easier to begin than car journeys.
In summary, the developer should be required to provide and implement: 1. A design code, specifying a) principles of street design and sustainable filtered permeability, to give a clear advantage to walking and cycling for all daily, local journeys by making secondary and tertiary roads safe for cycling and providing legible main cycling routes through residential areas, and b) house or apartment forecourt and garden layout which provides secure cycle parking closer to the front door than a car. 2. Gateway features on all access roads to the development physically and psychologically to indicate the transition into an area in which people and their safety have priority. 3. Legible and safe walking and cycling access points to the surrounding countryside on the A1198 at Caxton Gibbet and two other points, and financial contributions to provide safe and convenient walking and cycling access to surrounding settlements beyond these points and beyond the A428 at Caxton Gibbet and Cambourne Road. 4. Financial contributions to secure high quality, direct walking and cycling routes from homes in the development to and through the existing Business Park and Cambourne centre.
The purpose of all the above is to enable the achievement of the transport objectives stated in para 9.156. We believe that without the applications of such principles and guidance the objectives are unlikely to be achieved.
RW for Sustrans 6 February 2015