1 These representations are made on behalf of Mr K.B. Tebbit Ltd and relate to the promotion of HELAA sites Ref: 40383 – Land north east of Hurdleditch Road, Orwell and Ref: 40378 – Land to the south west of Hurdleditch Road, Orwell.

2 The GCLP states that the proposed development strategy to guide the growth of Greater Cambridge over the plan period supports “rural communities to thrive and sustain services”. In rural areas of Greater Cambridge the development strategy proposes a “a very limited amount of development” at small sites at villages which have “very good public transport access”.

3 After accounting for existing committed housing supply, the First Proposals document states that new sites to deliver 11,640 additional dwellings are needed to meet the housing need target. To help meet this new need the proposed development strategy seeks the allocation of four new sites in the rural area of Greater Cambridge, two of which are located in the “Group Villages” Caldecote and Oakington. These four sites can deliver 224 dwellings. This equates to the rural area delivering only 1.9% of the new housing supply need. This figure rises to 3.2% if the housing delivery associated with supporting jobs at research parks to the south of Cambridge is included.

4 The development strategy is heavily reliant on the delivery of new settlements and strategic sites with 62% of the total supply over the plan period coming from these sources. Strategic sites and new settlements are often complex developments to bring forward and implement with significant investment in infrastructure often required before dwellings can be delivered. It is acknowledged that these types of sites have a role to play in meeting housing needs, however, it is clear that the proposed development strategy is heavily reliant on such sites coming forward, to a point where it risks the deliverability of the GCLP.

5 The development strategy and approach to making new allocations will not facilitate the delivery of thriving rural communities and risks the vitality of key services over the plan period. The rationale for proposing allocations in Caldecote and Oakington as opposed to other available and suitable sites at other Group Villages is not evidenced robustly. It would appear that the Councils development strategy for rural areas has been one which in the main restricts development, and where allocations are proposed, the process of making allocations has been site-led rather than being led by an objective process which compares the sustainability credentials of sustainable rural settlements.

6 The First Proposals document and accompanying evidence base aims to support rural communities and sustain their existing service provision, but its current approach to making new housing allocations and supporting Neighbourhood Planning will not deliver on this aim.

7 Planning policies are required to significantly boost the supply of new homes and seeks a sufficient amount and variety of land to come forward to their objectively assessed housing need. The NPPF makes it clear that planning policies need to bring forward a mix and variety of housing land. The approach proposed through the GCLP does not represent a flexible and balanced approach capable of responding to changing circumstances or providing a mix and variety of sites. In addition, paragraph 69a) of the NPPF requires development plans to accommodate at least 10% of their housing requirement on sites no larger than one hectare. The development strategy proposes no new housing allocations on sites of less than 1ha. Instead, the GCLP relies on previous commitments to be delivered in the plan period and the potential for these smaller sites to come forward via windfall sites. Page 40 of the First Proposals document confirms that the new allocations of this type are not proposed as they would likely need to be directed to less sustainable locations, thus having a negative impact on climate change and requiring Green Belt releases. Our client strongly disagrees with the Councils justification in this regard as the content of the Housing Economic Land Availability Assessment (HELAA) demonstrates that there are a number of available sites for residential development, located outside of the Green Belt, at sustainable settlements such as Group Villages.

8 The GCLP’s focus on directing growth to New Settlements and strategic sites will significantly limit the supply of new housing sites being delivered by smaller and mid-sized (SME) housebuilders. Paragraph 69 of the NPPF makes it clear that small and medium sized sites can make an important contribution to meeting the housing requirement of an area. The Government is keen to see these types of sites come forward to boost supply, increase design quality, increase delivery rates and assist SME housebuilders generally. The lack of small and medium sized sites being delivered by the GCLP is contrary to paragraph 69 of the NPPF and will likely lead to a constrained housing land supply over the plan period and see less bespoke housing schemes being delivered at a time when there is national drive to boost design quality.

9 Over the current plan period and historically in Greater Cambridge there has been significant pressure placed upon the five-year housing land supply. This in part is due to the current over reliance on strategic sites and failure to allocate proportionate growth at established rural settlements which have fewer delivery constraints. Accordingly, promoting a development strategy which provides variety in making new allocations will safeguard against future shortfalls in five-year land supply and subsequent speculative development proposals coming forward. The GCLP and Neighbourhood Plans should take the lead by positively planning for new housing at established sustainable rural settlements, such as Group Villages, rather than being subject to future speculative development proposals at sites not allocated in a Local Plan when there is a deficit in supply across the plan area.

10 Alongside the total housing need requirement, the proposed development strategy should be reconsidered and amended to ensure that established settlements in the rural area benefit from sustainable levels of housing growth.