Question 31. How should the Local Plan help to meet our needs for the amount and types of new homes?

6.1 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed (NPPF Para. 59).

Question 31: How should the Local Plan help to meet our needs for the amount and types of new h omes? 4.4 The Greater Cambridge Local Plan provides a key opportunity to readdress the balance between economic growth and housing delivery. In order to ensure choice, affordability and diversity, the Local Plan must make provision for a sufficient quantity of housing. It must also include a range of housing types and sizes, across a variety of sites and locations. This should include small and medium sites, in addition to strategic sites, to ensure the ongoing delivery of housing throughout the plan period. In accordance with the NPPF (paragraphs 67 and 68), strategic policy-making authorities should identify a sufficient supply and mix of sites over the local plan period. 4.5 Determining the appropriate amount of housing to deliver in Greater Cambridge during the plan period is a critically important role for the Local Plan. It is essential that there is an adequate rate of housing completions across the plan period, maintaining a continuous five-year housing land supply to support economic growth and job creation, social cohesion and sustainable lifestyles. To ensure that delivery is continuous and consistent, a number of small- and medium-sized sites must be progressed. The NLP study of largescale site delivery ( Start to Finish , November 2016) highlights that lead-in times for large sites is 3.9 years and the planning approval period for schemes of 2,000+ dwellings averages 6.1 years. The research showed that the planning approval period increases significantly for sites in excess of 500 units. An over-reliance on large sites such as those currently proposed at Waterbeach and Bourn Airfield which require significant infrastructure provision will therefore undermine delivery and exacerbate the housing issues that exist at present.

6.1 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed (NPPF paragraph 59).

2.13 The Local Plan should meet housing needs by providing the necessary supply of housing. In doing so the Councils must allocate a sufficient number of sites to provide realistically deliverable developments, becoming available when they are needed. The National Planning Policy Framework (NPPF) sets out the Government’s objective of ‘significantly boosting the supply of homes’ and stresses the importance of providing ‘a sufficient amount and variety of land … where it is needed’ (Paragraph 59). The Council should therefore look to identify a wide range of sites across the full spectrum of development scales to ensure consistent delivery throughout the Plan period. 2.14 As stated at 2.5 it is acknowledged that Cambridge is surrounded by the Green Belt, and that Land at Ely Road, Milton is within the Green Belt. However, some Green Belt will need to be released to enable sufficient residential development to meet the growing needs of the area.

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

As explained within the previous submission to the SHELAA, there exists an extreme lack of residential moorings on the River Cam. Both Councils are aware of the issues around the availability of both narrow and wide berth boat licences. There is currently a 10 year waiting list for residential narrow boat licences and a 20 year wait for wide berth boat licences. Furthermore, the current facilities are substandard along the river with no refuelling station existing within Cambridge City. This results in boat users having to take their boats to Ely over 15 miles away to refuel. There is only one pump out point, where boat users can dispose of their raw sewage close to Jesus Green Lock. The only water point to fill the boat up with clean water is also located at Jesus Green Lock. The new Local Plan should acknowledge the different types of housing which the local population may require outside of the normal income measurements. It is important that housing for ‘different groups of the community’ and planning so that those ‘needs are met’. It is clear that in the two most recently adopted Local Plans for both Cambridge City and South Cambridgeshire, the needs of the river users who reside on the River Cam have not been met. It is imperative therefore that this Greater Cambridge Local Plan looks to understand and provide sufficient allocations for residential moorings, including continuing to allocate the Marina at Fen Road, however, it is also important that the proposed residential development on land adjacent to the River is also allocated for residential development, in what is a highly sustainable location.

6.1 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed (NPPF Para. 59). 6.2 The NPPF also advises that strategic policies in Local Plans should be informed by a local housing need assessment. Within this context, the size, type and tenure of housing needed for different groups in the community should be assessed and reflected in planning policies (including, but not limited to, those who require affordable housing, families with children, older people, students, people with disabilities, service families, travellers, people who rent their homes and people wishing to commission or build their own homes (NPPF Para. 60-61).

2.8 The Local Plan should meet housing needs by providing the necessary supply of housing. In doing so the Councils’ must allocate a sufficient number and scale of sites to provide realistically deliverable developments, which will come forward at the time that they are needed. The NPPF sets out the Government’s objective of ‘significantly boosting the supply of homes’ and stresses the importance of providing ‘a sufficient amount and variety of land … where it is needed’ (Paragraph 59). The Council should therefore look to identify a wide range of sites across the full spectrum of development scales to ensure consistent delivery throughout the Plan period. 2.9 It is acknowledged that Cambridge is surrounded by the Green Belt, and Land at Fulbourn Road, Teversham is within the Green Belt. Further commentary is provided on Green Belt release in a later section of these representations. It is however considered that some Green Belt will need to be released to enable sufficient residential development to meet the needs of the area.

3.33 Paragraph 72 of the National Planning Policy Framework 2019 recognises the role that larger scale development can have in supplying a large number and variety of new homes: “The supply of large numbers of new homes can often be best achieved through planning for larger scale development, such as new settlements or significant extensions to existing villages and towns, provided they are well located and designed, and supported by the necessary infrastructure and facilities”. 3.34 As part of a hybrid approach to the spatial strategy, the new Local Plan should allocate larger scale developments where new homes can be delivered in highly-accessible locations with walking, cycling and public transport links, promoting healthy living and sustainable lifestyles. Such development can deliver a wide range of housing types and tenures to meet housing needs across all groups in the community. 3.35 Growth on the edge of Cambridge has the benefit of being able to foster more sustainable travel patterns and promote change in behaviours so residents live and work more sustainably.

6.2 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed, as indicated by Paragraph 59 of the NPPF.

The new Local Plan should plan positively to allocate a sufficient amount of land to meet the needs of the communities and growing economy within Greater Cambridge. This means allocating enough land for both the projected housing needs of the area and additional land for housing to foster continued economic growth. As detailed in our response to Question 32 below, the government’s standard method for calculating housing need only identifies a minimum number of homes to be planned for. There is a need to plan for an increased level of housing in Greater Cambridgeshire to ensure that the Councils achieves their economic growth commitments and adopt a policy which aligns with the agreed positions within the Oxford-Cambridge Arc Joint Declaration of Ambition and the Cambridgeshire and Peterborough devolution deal. Furthermore, as set out in our response to Question 39, to ensure that the Local Plan provides for the quantum of development needed, it is highly unlikely that the emerging housing need can be entirely located on land either within existing settlements or on accessible land outside of the Green Belt. As such, the Greater Cambridge Local Plan should review the existing Green Belt boundaries.

6.1 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed (NPPF Para. 59).

The emerging GCLP will need to be consistent with national guidance on meeting housing needs. Paragraph 59 of the NPPF confirms the Government’s objective to significantly boost the supply of housing, and to achieve this by ensuring that a sufficient amount and variety of land for housing is identified. Paragraph 60 expects the standard method to be used to determine the minimum number of houses needed. Paragraph 61 expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. Paragraph 010 of Id.2a makes it clear that the standard method is the minimum starting point for determining local housing needs, and acknowledges that there may be circumstances where actual housing need is higher than the standard method indicates. As set out in Paragraph 010 the circumstances where increases to housing need that exceed past trends are as follows: there is a growth strategy in place to promote and facilitate additional growth; strategic infrastructure improvements are likely to lead to an increase in the number of homes needed locally; and, an authority has agreed to accommodate unmet housing needs from a neighbouring area. The first two circumstances are relevant to Greater Cambridge. Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. There is an urgent need to improve the affordability of housing and to boost affordable housing delivery in Greater Cambridge. Therefore, the emerging GCLP should use the standard method to calculate the minimum local housing need, and then make appropriate adjustments taking into account the growth strategies and strategic infrastructure improvements identified for Greater Cambridge, and a further adjustment to ensure affordable housing needs are met. It will also be important to ensure that the emerging GCLP allocates sites which have good prospects of deliverability within appropriate timescales. This is considered more important withing Greater Cambridge as new settlements allocated in previous Plans have been slow to deliver and this has had a negative effect on the supply of both market and affordable housing across Greater Cambridgeshire. Land to the east of the Ridgeway and Old Pinewood Way, Papworth Everard is being promoted by a housebuilder that would develop out the site themselves. The site has been subject to two previous planning applications and Bloor Homes Eastern remain committed to the delivery of housing at this site. Should the site be allocated, Bloor Homes Eastern would expect a delivery rate of 60 dwelling per year for a site of this size. The site could therefore be built out within 2.7 years once a start on site was made and therefore within the early years of the plan period.

5.1. Savills (UK) Ltd are instructed by Mr and Mrs Wilkinson to make representations to the Greater Cambridge Issues and Options Local Plan (January 2020) in respect of their land interests to the east of the A505 Royston. 5.2. We welcome the Councils acknowledgement that around 2,900 homes per annum (subject to further modelling) will need to be delivered to provide flexibility to support the growing economy. 5.3. As noted on page 61 of the Issues and Options plan, the Cambridgeshire and Peterborough Independent Economic Review (CPIER) (2018) has found that recent jobs growth in the region has been faster than expected, and this growth is likely to continue. House prices in Greater Cambridge are well above the national average, and economic growth is going to continue to place pressures on the housing market. 5.4. It is therefore crucial that the Local Plan looks to meet it housing targets across the plan period. A stepped approach to housing delivery will not be appropriate in an area such as Greater Cambridge where there is already acute affordability issues and, in the past, housing supply has failed to keep up with demand. 5.5. It is essential that the next Local Plan provides for a mix of homes across a range of different sites in different locations. As noted at paragraph 72 of the NPPF (2019), a supply of a large number of homes can often best be achieved through planning for larger scale development, such as significant extensions to existing villages and towns, provided they are well located and supported by the necessary infrastructure and facilities.

57. In order to adequately respond to changing housing needs over the Local Plan period, flexibility and variety in the amount and type of new homes is required. 58. As stated in response to Question 5, this can be achieved by avoiding reliance on a single growth strategy, and instead adopting a mixed and flexible approach to identifying and allocating new housing sites of different sizes and in different locations across the entire plan area. This will ensure a range of different housing types and products will come forward which are appropriate to the site context and development size and will help meet demand for housing in all locations including established settlements and villages. 59. Additionally, Cambridgeshire has significant housing affordability issue which will only increase as job growth continues, and the Greater Cambridge Plan must seek to significantly exceed minimum housing requirements to begin to rebalance this issue, and ensure a range of different affordable housing types can be delivered.

There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed (NPPF Para. 59).

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

2.43 The sites proposed at Steeple Morden are demonstrably available and deliverable without being constrained and could provide a suitable mix of market, affordable and entry-level housing, that will comply to national space standards and can be defined as accessible homes.

6.1 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed (NPPF Para. 59).

The Local Plan should ensure it takes a positive and ambitious stance towards housing growth, as stated in Paragraph 119 of the NPPF, local planning authorities should take a proactive role in identifying and helping POT208/L0004 Land North of West Road, Gamlingay 3 | P a g e bring forward land that may be suitable for meeting development needs. There is a clear demand for additional housing in the Greater Cambridge area, especially with the forecasted increase in employment growth. The Local Plan must ensure there is a wide range and choice of residential dwellings available, including in rural and urban areas. Local Plan policy should be in line with Paragraph 59 of the NPPF which states that policy should support the Government’s objective of significantly boosting the supply of homes, ensuring that a sufficient amount and variety of land can come forward where it is needed. The ageing population of South Cambridge is expected a growth forecast between 2001-2021 of 95% for the 6074 age group and 108% for those over 75. The needs of the district are changing, and the new Local Plan must ensure it has catered for different sections of society. With an ageing population, there is a need for the deliverability of homes available for downsizing or ‘lifetime’ homes. As clarified in Paragraph 22 of the NPPF, strategic policies should look ahead over a minimum of a 15-year period from adoption, to anticipate and respond to long-term requirements and opportunities, including preparing for demographic changes in the population and catering to its needs. The local plan must prepare for the future growth of the Greater Cambridge Area by providing and allocating a sufficient supply of homes which in turn will deter unsustainable and unsuitable developments. The Greater Cambridge area has been affected by increasing house prices which coupled with growing demand for the past decade. By providing an ample supply of homes as well as the provision for affordable housing, it ensures residents do not have to leave their communities in search for more affordable accommodation. As part of the preparation for the Gamlingay Neighbourhood Plan, a Housing Needs Survey was published in 2017. The response for the survey was 22.4% which stated that Gamlingay should consider the housing demands of people moving to Gamlingay from the surrounding area and further afield in particular; older homeowners, families wanting to move to a village location to raise children and younger single persons households, or couples. Therefore, both in respect of the needs of the plan area and the localised needs of the village, it is important that an ambitious growth target is set for Gamlingay within the plan.

At this stage, the average annual requirement for Greater Cambridge is to ensure sufficient land is identified to deliver a minimum 1,800 dwellings per annum (using the Governments standard methodology) or 2,900 dwellings per annum to deliver jobs related growth by 2040. To achieve this, it will need a selection of options and choice of sites to sustain the pace of delivery. There should be a spread of delivery over the period to 2040 to ensure the market can support the step change in the level of growth envisaged through the economic growth model. The under-delivery in the GCLP area underscores the importance of providing a range of deliverable sites in a range of sustainable locations across the whole plan area, with villages being a critical location for achieving a successful spatial strategy to 2041 and beyond. Opportunities for growth and investment need to be provided across the unitary area and in locations that provide the greatest potential to unlock economic growth and improve sustainable connectivity. It also avoids over-concentrating growth in locations which already have significant commitments, which could risk delay and stagnation in housing delivery. There is a risk that seeking to allocate too many homes based on similar principles to the 2018 Local Plans could impact upon delivery rates and consequently investment in the area. Housebuilders will only ever be able to maintain a set number of outlets on site at a given point in time. Allocating more housing to a location already benefitting from high amount of commitments is unlikely to have a proportionate impact upon housing delivery for these reasons. The GCLP should recognise that there is a need to ensure a balanced strategy for growth across the area including at established villages in highly sustainable locations. These settlements have a role to play in supporting sustainable economic growth for the GCLP. This is consistent with the PPG. We consider that a balanced portfolio of housing sites in terms of geography, quantum and tenure is essential to the success of the GCLP. To deliver growth, and particularly the higher economic growth-scenario, there is a need to utilise different approaches of delivery in order to meet geographical need and to ensure a consistent stream of housing completions. This includes locations such as Great Shelford. It is not appropriate to assume that Neighbourhood Plans will provide any meaningful additional housing in existing villages to 2040 evidenced by the lack of take up by parishes and local communities unless the GCLP directs a Neighbourhood Plan group to do so. Of the 100+ villages in the GCLP area, only 18 have designated NP areas and only one Neighbourhood Plan has been made at the time of writing. The importance of preparing strategic policies that include a housing requirement for designated Neighbourhood Areas is set out in para 65 of the NPPF as follows “Strategic policy-making authorities should establish a housing requirement figure for their whole area, which shows the extent to which their identified housing need (and any needs that cannot be met within neighbouring areas) can be met over the plan period. Within this overall requirement, strategic policies should also set out a housing requirement for designated neighbourhood areas which reflects the overall strategy for the pattern and scale of development and any relevant allocations”. It goes on to state that “once the strategic policies have been adopted, these figures should not need retesting at the neighbourhood plan examination, unless there has been a significant change in circumstances that affects the requirement”. This guidance would capture some of the sustainable villages which have designated Neighbourhood Areas including Great Shelford (Stapleford and Great Shelford NP area was designated in November 2016) but which progress has been slow. Further development in this location would help to address current affordability challenges. The high house prices and affordability ratio in South Cambridgeshire area suggests that it is particularly difficult for people to access the housing market. Applying this to Great Shelford where the census data shows similar trends leads us to conclude that the settlement would benefit from a future increase to housing supply. An increase in housing stock in Great Shelford would mean that it would be easier for people to access the local housing market and/or remain resident in the local area at the stage in which they require alternative forms of accommodation, such as older persons housing. To achieve this, a housing target and potential green belt releases should be identified within the GCLP.

2.50 A specific response has been provided to questions 31 & 32 in the accompanying representations by Barton Willmore on behalf of our client with regard to the amount and type of housing provision. However, in summary our view is that enough allocations need to be made in sustainable locations with clear policies on the market housing mix and facilitation of the broadest range of affordable housing tenures as set out by the NPPF. In particular it will need to ensure the economic success of the Greater Cambridge area is not hampered by inadequate housing delivery and transport infrastructure and tackle sustainability in a holistic way, rebalancing growth in the area to respond positively to the identified four big themes. 2.51 In that context, we would advocate allocating the widest possible range of sites in order to provide a more sustainable development strategy and rebalance Greater Cambridge growth needs. This will include allocating sufficient land for small-medium housing sites in rural settlements, which can deliver quickly and improve the rate at which houses can be absorbed by the market. As has been set out previously within this consultation response, the proposals for Comberton will see the provision of housing to meet a wider range of needs from homes for first time buyers through to later living provision, all successfully integrated into the master plan and Comberton more generally. The development will also provide affordable housing across a range of tenures, and also has the potential to meet any demand identified for self-build plots.

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

3.19 It is important that the new Local Plan seeks to allocate a suitable number of medium sized sites that can be developed in the short term. It is also important that growth is dispersed to some of the larger and most sustainable villages outside of the Green Belt. 3.20 According to the NPPF, the Planning Practice Guidance, and Planning Inspector’s Report on the South Cambridgeshire Local Plan (2018), the Greater Cambridge Local Plan should meet housing needs through development of medium sized sites, as well a large strategic sites. Medium sized sites present an under-utilised opportunity for both residential and commercial development, overlooked and undercapitalised in the adopted South Cambridgeshire Local Plan (2018) and the Cambridge City Local Plan (2018). 3.21 In the Planning Inspectors’ Report of the South Cambridgeshire Local Plan (2018), it was recognised that “a significant proportion of the overall housing requirement will be provided in major allocations”. Considering this, the potential of smaller sites have in helping to “diversify the house building sector by providing a boost to small and medium sized developers” was recognised, with a recommendation to allocate housing in individual villages. 3.22 In order to be considered sound, regard should be given to the Planning Inspectors’ Report, along with NPPF paragraph 68, which states that: “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly”. 3.23 Paragraph 68 goes onto state that this can be achieved by allocating a higher amount of small to medium sized sites, rather than less large strategic allocations, or working with developers to encourage the sub-division of large sites, helping to speed up the delivery of homes. Additionally, the Planning Practice Guidance identifies the need to consider a range of sites for development, including medium sized sites in villages and towns. The land adjacent to Balsham Road, Linton is of a size that could be delivered quickly, within the short term and within the first 5 years of the Local Plan. 3.24 It is also very important that a suitable quantum of growth is dispersed to the most sustainable and largest villages outside of the Green Belt, such as Linton. 3.25 Linton is located in a very sustainable location and benefits from being very close to key employment clusters to the east of Cambridge. Reflected in both national policy and the themes of the Greater Cambridge Local Plan, is the location of residential development being in proximity to a variety of employment opportunities, which will minimise the need of residents to commute long distances to work. Only 4.5 kilometres north-west of Linton is Granta Park, a 24 acres a science and business park with a direct commuter bus running from Linton. Furthermore, Genome Campus, a genomics and biodata park consisting of over 2,600 students and employees, is located approximately 6.5 kilometres south east if Linton. 3.26 At 9.8 hectares, the site promoted in the Call for Sites is an example of a medium sized site adjacent to an existing sustainable village, which is able to make an important contribution to local housing requirements in a relatively quick time frame. Countryside Properties have a proven track record of the delivery of mixed use housing led sites and are committed to delivery of the development early on within the plan period.

6.1 There should be flexibility within the Local Plan to respond to changing housing needs over the Local Plan period. It is important to identify a baseline housing need but there should be scope for further development to come forward if it meets a particular housing need. This would support the Government’s objective of significantly boosting the supply of homes to ensure that a sufficient amount and variety of land can come forward where it is needed and that the needs of groups with specific housing requirements are addressed (NPPF Para. 59). 6.2 The emerging GCLP will need to be consistent with national guidance on meeting housing needs. Paragraph 59 of the NPPF confirms the Government’s objective to significantly boost the supply of housing, and to achieve this by ensuring that a sufficient amount and variety of land for housing is identified. Paragraph 60 expects the standard method to be used to determine the minimum number of houses needed. Paragraph 61 expects the size, type and tenure of housing needs of the community to be assessed and reflected in planning policies, including for example those with an affordable housing need, students, renters and self-builders. Section Id.2a of the Planning Practice Guidance explains how housing and economic needs assessments should be undertaken, including how to calculate local housing needs using the standard method. 6.3 Paragraph 010 of Id.2a makes it clear that the standard method is the minimum starting point for determining local housing needs and acknowledges that there may be circumstances where actual housing need is higher than the standard method indicates. As set out in Paragraph 010 the circumstances where increases to housing need that exceed past trends are as follows: there is a growth strategy in place to promote and facilitate additional growth; strategic infrastructure improvements are likely to lead to an increase in the number of homes needed locally; and, an authority has agreed to accommodate unmet housing needs from a neighbouring area. The first two circumstances are relevant to Greater Cambridge. Paragraph 024 of Id.2a explains how the need for affordable housing is calculated, and it is suggested that the overall housing target should be increased where it could help deliver the required number of affordable homes. There is an urgent need to improve the affordability of housing and to boost affordable housing delivery in Greater Cambridge. 6.4 Therefore, the emerging GCLP should use the standard method to calculate the minimum local housing need, and then make appropriate adjustments taking into account the growth strategies and strategic infrastructure improvements identified for Greater Cambridge, and a further adjustment to ensure affordable housing needs are met.

19. The Local Plan should help meet our needs for the amount and types of new homes through a blended spatial strategy that focuses on sustainable locations that are well-connected or have the potential to be connected to high quality public transport. Whilst also recognising that a range of sites is required to aid deliverability and to ensure that all villages can grow in a sustainable manner appropriate to their size and scale. 20. The housing market area for Greater Cambridge is a very challenging one. Affordable housing delivery is a significant problem with high levels of demand for affordable and key worker housing. The ageing population will also add significantly to the demand for specialist housing. Consequently, the new plan needs to be very ambitious in terms housing delivery to ensure that there is a significant supply and mix of deliverable housing sites across the plan area, in excess of the levels of identified need, to boost delivery and help maintain competition in market and drive affordability. 21. The joint Inspector’s Report on the Examination of the South Cambridgeshire Local Plan (August 2018) noted that “The Plan proposes that development needs will be met at two new settlements at Waterbeach and Bourn Airfield. We have some concerns regarding the challenges of delivering new development at Waterbeach and Bourn…” However, because these development sites were not required to deliver housing in the early part of the plan period, the Inspectors concluded that due to the plans commitment to an early review there would be an opportunity to review progress as part of the preparation of the new joint local plan. 22. We consider the Inspector’s concerns to be justified and that the new plan should include a range of allocations including small and medium size sites throughout the area to ensure that rural settlements have the opportunity to grow and thrive in line with National Planning Policy advice. 23. It is import to note that the Inspector for the Uttlesford Local Plan Examination recently wrote to the Council on the 10th January 2020 raising significant concerns in relation to the soundness of the plan. In particular, in respect of the overall spatial strategy which relies on the development of three Garden Communities. 24. This reinforces the essential need for the new Greater Cambridge Local Plan to be based on a blended strategy which builds on the existing urban extensions already allocated around Cambridge and the strategic growth proposed at Cambourne, Northstowe, Waterbeach and Bourn Airfield through the allocation small and medium sized sites across the plan area. This is imperative to not only maintain supply and flexibility but to ensure that the rural areas can prosper and thrive and are not left behind. 25. Summary: The Local Plan should adopt a blended approach including a range of locations, and site sizes to ensure deliverability and choice in the market.

It is a statutory requirement for Local Plans to address the housing requirements of their local plan area. This includes providing strategic policies to identify the requisite scale of development as well as the quantum of development, particularly housing numbers to meet the identified need of the Plan area over the established Plan period and reflect economic growth requirements. Paragraph 20a of the National Planning Policy Framework asserts that Plans should make sufficient provision for multiple elements of development, including housing, retail and other commercial development. As such, it is a fundamental priority for the emerging Local Plan to ensure that an appropriate objectively assessed need, underpinned by the relevant evidence, is identified and that this need can be realistically delivered over the Plan period. The Plan should also engage a deliverable spatial strategy that has the ability to provide a basis for growth that can accommodate the necessary housing requirement. The adoption of a realistic spatial strategy will contribute towards the Plan's ability to satisfactorily deliver the requisite housing numbers over the Plan period. An effective spatial strategy should consider all options in terms of locations and the distribution of development. Given that the Greater Cambridge area includes vastly different spatial characteristics, ranging from dense urban landscapes to rural village locations; the spatial strategy should positvely respond by allowing for a distribution of development and varying spatial options to accommodate development. It is considered that no single spatial option represents the most appropriate approach and instead the Plan should adopt a flexible approach to its emerging spatial strategy, by not precluding any possible avenues at this early stage. Southern & Regional Developments (Cottenham) recognise that large quantums of development for housing and employment purposes are best focused upon the larger settlements and sustainable expansion of Cambridge. Alongside this the strategy should seek to provide development opportunities at smaller settlements where growth can be accommodate through amendment to Development Frameworks. Achieving development at sustainable settlements across the hierarchy would be able to deliver affordable homes and also provide new houses to address high house prices within rural locations where the lack of new housing stock has articfically inflated values. Summary of Comments: Adoption of a flexible and considered spatial strategy will contribute towards delivering the housing numbers the Plan needs to meet demand.

15. According to the NPPF, the Planning Practice Guidance and the Planning Inspector’s Report on the South Cambridgeshire Local Plan (2018), the Greater Cambridge Local Plan should meet housing needs through the development of small scale sites, such as those put forward by our client as well as large strategic sites. 16. The NPPF states in paragraph 68 that “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.” 17. This can be achieved by allocating a higher amount of small to medium sized sites, rather than large strategic allocations. Additionally, the Planning Practice Guidance identifies the need to consider a range of sites for development, including small scale sites in villages and towns. Furthermore, allocation of smaller sites supports South Cambridgeshire District Council’s wish to support local Small and Medium Enterprises for reasons of the local economy and journeys to work. Our client is pleased that a local building firm is currently carrying out the conversion of the permitted development barns south of the land North of Fenny Lane.

5.24 This can principally be achieved through the reduced use of polluting vehicles by: ● Locating development where there is good access to active travel, coupled with access to affordable, frequent, reliable and high quality public transport options; ● Better cycle and pedestrian connectivity – achieved by developments directly and through a coordinated s106 infrastructure programme; ● Developing the infrastructure for battery powered travel and encouraging/incentivising car sharing arrangements.

16. According to the NPPF, the Planning Practice Guidance and the Planning Inspector’s Report on the South Cambridgeshire Local Plan (2018), the Greater Cambridge Local Plan should meet housing needs through the development of small scale sites, such as those put forward by my client as well as large strategic sites. The supporting Greater Cambridge Housing Delivery Study prepared by Barton Willmore draws attention to slow delivery rates and a concentration of large sites to the north of the district. It notes that ‘Greater Cambridge has seen several large-scale strategic housing sites and long lead in times for new settlements such as Cambourne and Northstowe’. It concludes that while ‘Generally, large sites deliver more housing each year on average, but the advantage of smaller sites is that they tend to build out quicker and have shorter lead-in times overall when considering the planning approval process’. For this reason, village sites such as land to the rear of Fisher’s Lane, Orwell have an important role in delivery and achieving a mix of housing. 17. NPPF Paragraph 68 sets out that “Small and medium sized sites can make an important contribution to meeting the housing requirement of an area, and are often built-out relatively quickly.” This can be achieved by allocating a greater number of small to medium sized sites, rather than fewer large strategic sites or working with developers to encourage the sub-division of large sites, helping to speed up the delivery of homes. Additionally, the Planning Practice Guidance identifies the need to consider a range of sites for development, including small scale sites in villages and towns. 18. The existing planning strategy places a significant reliance on the strategic allocations around the City and also the development of new settlements which the Inspector’s raised concerns about. The new Local Plan should significantly increase the allocation of small to medium sized sites in the rural areas, to help speed up delivery of homes and allow more flexibility. Small-medium sized sites play an important role in providing a wide variety Greater Cambridge Local Plan Issues and Options 2020 Consultation of house types and mix and also deliver quickly compared to larger sites. In accordance with Paragraphs 67 and 68 of the NPPF, strategic policy-making authorities should identify an appropriate supply and mix of these sites across the District and Local Plan period. 19. Summary: The Local Plan should adopt a blended approach including a range of locations, and site sizes to ensure deliverability and choice in the market.