Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57113

Received: 09/12/2021

Respondent: Cambridge District Oddfellows

Agent: Carter Jonas

Representation Summary:

Summary: Land at Two Mill Field (HELAA site 40419) & land north of Oakington Road (HELAA site 40247)

Additional sites that are capable of providing policy compliant levels of affordable housing need to be identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

Small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, including Cottenham, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable and community land trust housing in those villages.

Land at Two Mill Field and the land north of Oakington Road in Cottenham should be allocated in emerging GCLP for residential development.

Full text:

OBJECT

Cambridge District Oddfellows is promoting land at Two Mill Field and land north of Oakington Road in Cottenham for residential development, and in representations has requested that these sites are allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the rest of the rural area, and specifically the decision to allocate a very limited amount of development to the more sustainable villages.

The overall development strategy is very reliant on the delivery of an extensions to an existing new settlement (Cambourne West + an additional 1,950 dwellings at Cambourne), planned new settlements (Northstowe, Waterbeach and Bourn Airfield) and new communities on the edge of Cambridge (North East Cambridge and Cambridge East). It is acknowledged that the principle of development at most of these strategic sites is already established through adopted development plan documents; the additional dwellings at Cambourne is proposed through emerging GCLP and associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy, which relate to housing delivery rates and whether these can be increased at some new settlements, the relocation of existing uses from some sites, and the delivery of affordable housing.

The most recent housing trajectory for Greater Cambridge (published April 2021) already predict high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and Bourn Airfield are predicted to deliver a combined total of 300 dwellings per annum. Cambourne has historically delivered approximately 230 dwellings per annum. Hampton (in Peterborough) has historically delivered 259 dwellings per annum. Cranbrook (in East Devon) which has the highest annual delivery rate of current new settlements is delivering at 295 dwellings per annum). The Inspector for the Huntingdonshire Local Plan recommended that the combined housing delivery rates Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum, and for St Neots East (Loves Farm and Wintringham Park) should be no higher than 200 dwellings per annum. The predicted average housing delivery rates at Northstowe, Waterbeach and Cambourne West/Bourn Airfield already appear to be at levels comparable to or higher than other new settlements elsewhere. It is likely that current predicted delivery rates are already optimistic, but there is no credible evidence that faster housing delivery rates can be achieved at Northstowe or Waterbeach. It is noted that Cambourne, Hampton and Cranbrook all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. It is requested that predicted housing delivery rates for the new settlements take into account the above comments, and the assumption that faster housing delivery rates can be achieved at Northstowe and Waterbeach should be deleted from the development strategy.

North East Cambridge and Cambridge East are allocated in both Local Plans as strategic sites. It is acknowledged that these sites involve the re-use of previously developed land. However, the redevelopment of these sites is complex and involves the relocation of the existing uses; the relocation of a sewage treatment works and existing businesses in the case of North East Cambridge, and the relocation of airport related uses and businesses in the case of Cambridge East. It is considered that the delivery of development at these sites will need to be realistic, taking into account all of the challenges that need to be overcome prior to the commencement of development. It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is noted that most of the new settlements will deliver less affordable housing than the normal policy requirement of 40%, mainly because of the need for these developments to also deliver significant levels of new transport and community infrastructure in initial phases. The affordable housing contributions are as follows: 20% at Northstowe, 30% at Waterbeach, 30% at Cambridge East (Wing), 30% at Cambourne West and 40% at Bourn Airfield, although all are subject to a review mechanism that could result in adjustments to the level of affordable housing. The proportion of affordable housing that will be provided from the developments at North East Cambridge and Cambridge East are unknown at this stage, but because of the costs associated with the relocation of existing uses and the delivery of new transport infrastructure it is very unlikely that 40% affordable housing will be provided at least in the initial phases. It is clear that the existing and planned new settlements and new communities in the edge of Cambridge are not and will not provide enough affordable housing, which should be a concern in an area such as Greater Cambridge which has significant housing affordability issues. It is requested that, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East, the development strategy should allocate additional sites that are capable of providing policy compliant levels of affordable housing including small and medium sites in the villages.

The preferred development strategy for the rest of the rural area is based on the assumption that the villages in this area are unsustainable because existing and future residents would need to travel by car to access services and facilities and employment opportunities. It is considered that this assumption is incorrect for some villages, including Cottenham, which contain a good range of services and facilities and is accessible by sustainable modes of transport. In addition, the preferred development strategy for the rest of the rural area provides no support for existing services and facilities in villages and provides no strategy to meet current identified affordable housing needs of villages. Cambridge District Oddfellows are not advocating a dispersed development strategy whereby most development is directed to the villages, but is requesting that a sufficient amount of land is allocated at the more sustainable villages to support services and ensure that identified affordable housing needs are met.

There are three paragraphs in the NPPF that suggest a different approach is required in the development strategy for the rest of the rural area. Paragraph 105 seeks to ensure that development is located where the need to travel will be minimised and the use of sustainable transport modes can be maximised, but acknowledges that the opportunities will be different in urban and rural areas. Paragraph 79 seeks to promote sustainable development in rural areas by locating housing where it will enhance or maintain the vitality of rural communities and enable villages to grow and thrive. Paragraph 62 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.

Cottenham is designated as a Rural Centre; Cambridge District Oddfellows objects to the decision to reclassify Cottenham as a Minor Rural Centre in Policy S/SH: Settlement Hierarchy. Cottenham has a good range of services and facilities including a supermarket and convenience stores, post office, doctors surgeries, dentist, library, public houses, restaurant/takeaway, bank, primary schools and secondary school, village hall and meeting spaces. The promoted developments at land at Two Mill Field and at land north of Oakington Road would support the existing services and facilities in the village.

The promoted developments at land at Two Mill Field and at land north of Oakington Road would be accessible by walking, cycling and public transport to the services and facilities within the village. Cottenham is currently connected to Cambridge by frequent bus services. It is noted that the Greater Cambridge Partnership’s Making Connections project proposes substantial improvements to the bus services for Cottenham, including a bus every 10 minutes to Cambridge via Histon, a more frequent service to Oakington, and a more frequent rural service to Chatteris via Wilburton, Haddenham, Sutton and Mepal. These improvements to the bus service to and from Cottenham are not reflected in the decision to reclassify the village as a Minor Rural Centre or in the decision to not make any allocations in the village.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 52 affordable dwellings in Cottenham for those with a local connection to the village – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. It is acknowledged that the recent planning permissions for housing in Cottenham would meet most of the current identified affordable housing needs, although further affordable housing needs will arise during the plan period to 2041 and additional allocations should be made to meet those future needs. As a Rural Centre and one of the more sustainable settlements in South Cambridgeshire, Cottenham should seek to accommodate district-wide affordable housing needs and not just those from the village and the immediate surrounding area. The made Cottenham Neighbourhood Plan allocates three previously developed sites for housing, but it is noted that these sites fall below the site size threshold where affordable housing would be required, and as such no affordable housing would be delivered from these sites. There is a Cottenham Community Land Trust, but no schemes to deliver housing have been identified and the organisation appears to be having some difficulty in finding suitable sites. The promoted developments by Cambridge District Oddfellows at land at Two Mill Field and land north of Oakington Road in Cottenham could include a proportion of land for a community land trust scheme, in conjunction with a development for housing and affordable housing if the site is allocated in emerging GCLP.

For all these reasons, small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, including Cottenham, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the village, and there is an identified need for affordable and community land trust housing in the village.

Requested Change

The following changes are requested to Policy S/DS: Development Strategy:

It is requested that predicted housing delivery rates for the new settlements take into account the evidence from similar development elsewhere.

It is requested that the assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

It is requested that realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

It is requested that additional sites that are capable of providing policy compliant levels of affordable housing are identified in the development strategy, including small and medium sites in the villages, in order to address the under-delivery of affordable housing from Northstowe, Waterbeach, Cambourne West, North East Cambridge and Cambridge East.

It is requested that small scale housing allocations should be made in the more sustainable villages within the rest of the rural area, including Cottenham, because those villages are accessible by sustainable modes of transport, there is a need to support the existing services and facilities within those villages, and there is an identified need for affordable and community land trust housing in those villages.

As requested in the Cambridge District Oddfellows representations to Section 2.6: Rest of Rural Area, the land at Two Mill Field and the land north of Oakington Road in Cottenham should be allocated in emerging GCLP for residential development.