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KG Moss Will Trust is promoting land off Home End and the Moss Family is promoting land at Court Meadow House off Balsham Road, both sites are in Fulbourn. In representations it is requested that the sites are allocated for residential development 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 close to Cambridge such as Fulbourn and the decision to not release additional land from the Green Belt.

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 promoted developments by KG Moss Will Trust/Moss Family in Fulbourn are located within the Green Belt, and in these representations it is requested that the sites are released to accommodate housing and affordable housing with reference to Chapter 13 of the NPPF.

Paragraph 140 of the NPPF allows Green Belt boundaries to be altered through the plan-making process provided exceptional circumstances exist, and those exceptional circumstances should be based on evidence and justified. It is considered that exceptional circumstances exist to release land from the Green Belt, which are related to the significant need for housing and affordable housing in Greater Cambridge and the need to support economic growth. The exceptional circumstances to release land from the Green Belt applies to all parts of Cambridge covered by this designation and not just the Rural Southern Cluster as indicated in emerging GCLP. For example, Fulbourn is very well related to the employment opportunities within and on the edge of Cambridge including Peterhouse Technology Park and Capital Park, it contains a very good range of services and facilities and is accessible by sustainable modes of transport, and there is an identified need for affordable housing which is not being addressed through the emerging neighbourhood plan or by the emerging GCLP.

Paragraph 141 requires plan-making authorities to examine all other reasonable options to meet identified development needs before considering whether exceptional circumstances exist to justify changes to Green Belt boundaries i.e. make as much use of previously developed land, increase the density of development, and consider whether development needs could be accommodated in neighbouring areas. In the case of Cambridge increasing densities and reusing previously developed land is not straightforward and may be inappropriate because of heritage assets and the difficulty of finding alternative sites for existing uses. The adopted Local Plans for Cambridge and South Cambridgeshire already identified previously developed land opportunities, and the emerging GCLP seeks to do them same. As such, previously developed land opportunities that are deliverable have already been identified within and on the edge of Cambridge.

Paragraph 142 requires any review of Green Belt boundaries to consider the need to promote sustainable patterns of development, and that where the release of land from the Green Belt is necessary that priority is given to previously developed land or sites that are well-served by public transport. It is acknowledged in emerging GCLP and the associated Sustainability Appraisal that the edge of Cambridge is a sustainable location because of its close proximity to employment and the opportunity to travel by non-car modes of transport. Fulbourn is well served by public transport and is well connected with existing cycle routes, and there are plans to improve the walking and cycling connections to Cambridge. Therefore, the release of suitable land from the Green Belt on the edge of Fulbourn would be consistent with the approach in national policy to give priority to those Green Belt sites that are well served by public transport.

As set out in representations to Section 2.6: Rest of Rural Area and the HELAA Site Assessments (for Site Refs. 40522 and 40523), the land off Home End and the land off Balsham Road (as amended) in Fulbourn makes a limited contribution to openness and the purposes for including land within the Green Belt and should be released from the Green Belt in emerging GCLP.

The preferred development strategy for the rural area on the edge of Cambridge 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 Fulbourn, which is a sustainable village.

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.

Fulbourn is defined as a Minor Rural Centre in the settlement hierarchy. It contains a good range of services and facilities, including a primary school, doctor’s surgery, pharmacy, library, post office, supermarket and other small convenience stores, village hall, and outdoor recreation and play facilities. The promoted developments by KG Moss Will Trust/Moss Family in Fulbourn would support the existing services and facilities within the village. There are regular bus services to Cambridge, Haverhill, and Newmarket from Fulbourn, and there is a cycle route between Fulbourn and Cambridge. The Greater Cambridge Partnership has proposed a greenway (walking and cycling route) between Fulbourn and Cambridge. The Greater Cambridge Partnership’s Making Connections project seeks to improve the frequency of bus services from Fulbourn, including to Cambridge, Cambridge Station, Cambridge Biomedical Campus, and the proposed Cambridge South Station. Therefore, there are numerous options for residents of Fulbourn to travel by sustainable modes of transport for most journeys to access employment, education, and leisure.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified a need for 65 affordable dwellings in Fulbourn for those with a local connection to the village, and affordable housing needs in the neighbouring villages of Teversham (21 dwellings) and Great Wilbraham/Little Wilbraham (6 dwellings) – see https://www.scambs.gov.uk/media/18316/affordable-housing-housing-statistical-information-leaflet-december-2019.pdf. This identified need would not be met without additional allocations in Fulbourn. It is noted that the emerging Fulbourn Neighbourhood Plan makes no new housing allocations despite the need for affordable housing being identified as an issue for the local community. There is no community land trust in Fulbourn. Rural housing exception schemes are typically very small and are reliant on a landowner willing to offer land up at existing use value. The promoted developments by KG Moss Will Trust/Moss Family in Fulbourn would include housing and affordable housing to meet local needs of the village.

For all these reasons, small scale housing allocations should be made in the more sustainable villages in the rural area on the edge of Cambridge including at Fulbourn, because it is accessible by sustainable modes of transport, there is a need to support the existing services and facilities within the villages, and there is an identified need for affordable housing in the villages which would only partially be met by other developments.

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 in the rural area on the edge of Cambridge including Fulbourn, 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 housing in the village.

As requested in KG Moss Will Trust/Moss Family’s representations to Section 2.6: Rest of Rural Area, the land off Home End and the land at Court Meadows House off Balsham Road (as amended) in Fulbourn should be released from the Green Belt and allocated in emerging GCLP for residential development.