These representations to Policy S/DS are focussed on the preferred development strategy for the rural area, and specifically the decision to allocate a very limited amount of development within/adjacent to villages.

The development strategy presented within the GCLP is reliant on the delivery of extensions to Cambourne (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 and the additional dwellings at Cambourne are proposed through the emerging GCLP and are associated with East West Rail. However, it is considered that there are a number of risks associated with the preferred development strategy. These risks relate to housing delivery rates, whether delivery rates can be accelerated/increased at some of the new settlements as is proposed, 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 annual housing delivery rates for the new settlements. Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Cambourne West and Bourne Airfield are predicted to deliver a combined total of 300 dwellings per annum.

By way of a comparison, 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 one of the highest annual delivery rates of current new settlements across the country is delivering at 295 dwellings per annum.

In the cases of Cambourne, Hampton and Cranbrook, these new settlements all had multiple housebuilders on site at the same time and delivered affordable and market housing in conjunction with one another. Many new settlements are however unable to achieve annual levels of growth of 250 dwellings+ per annum with the number of new homes able to be delivered affected by many factors such as the number and geographical location of competing new settlement sites.

The Inspector for the Huntingdonshire Local Plan carefully considered the matter of delivery rates and the new settlement locations proposed within the neighbouring authority area of Huntingdonshire and recommended that the combined housing delivery rates for Alconbury Weald (the former Alconbury Airfield and Grange Farm) should be no higher than 300 dwellings per annum. For St Neots East (Loves Farm and Wintringham Park) it was concluded that the combined housing delivery rates should be no higher than 200 dwellings per annum.

The predicted average housing delivery rates at Northstowe, Waterbeach and Cambourne West/Bourn Airfield are therefore already very ambitious and are at a level comparable to those new settlements whose annual delivery rates are amongst the highest in the country. The current predicted delivery rates are considered to be very optimistic and carry risk given they form such a significant part of the planned housing trajectory. With this in mind, there does not appear to be any credible evidence to support increasing these already ambitious housing delivery rates at Northstowe or Waterbeach to help further boost assumed delivery rates within the GCLP.

It is requested that the predicted housing delivery rates for the new settlements be reviewed in the context of 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 Adopted 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. The delivery of 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.

As well as the above concerns about the overall delivery of new homes, it is also 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 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 on the edge of Cambridge are unlikely to provide enough affordable housing, which should be a concern in an area such as Greater Cambridge which has significant housing affordability issues. In order to address any 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. Very few allocations in villages are however included in the GCLP

The preferred development strategy for the rest of the rural area is based on the assumption that the villages 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, particularly for those villages which contain a good range of services and facilities.

In addition, the preferred development strategy which limits growth in the rest of the rural area provides no support for existing services and facilities in villages and provides no strategy to meet the current identified affordable housing needs of the villages.

While MPM Properties (TH) Ltd and Thriplow Farms Ltd are not advocating a dispersed development strategy, a sufficient quantum of land does need to be allocated in the right locations at the more sustainable villages to support services and ensure that the identified affordable housing needs of local communities are met.

There are three paragraphs in the NPPF that support more growth being directed towards 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.

MPM Properties (TH) Ltd and Thriplow Farms Ltd are promoting the site known locally as the Grain Store Site that is located off Lodge Road in Thriplow. The Grain Store Site is land has been previously promoted by a different promoter through the call for sites process (site reference 47379). At the time of the call for the sites submission, the previous promoter identified the indicative capacity of the site as being up to 36 dwellings. The site area has since been reduced with the commercial building known as Revivals, located within the south east corner, being removed from the proposed development area, it being a local employment site.

Given the concerns expressed above about the development strategy for the emerging GCLP, it is considered that sites such as the Grain Store site in Thriplow are suitable and available for allocation within the GCLP. Such locations that enjoy good access to local facilities, can help support local services in the future, help address local housing need and deliver sustainable growth should be assessed for future allocation within the GCLP. The delivery of housing in such locations would not only support the delivery of new homes across the Greater Cambridge area, reducing the pressure/reliance on the small number of larger sites identified, but would also address local housing need.

On the subject of housing need, the draft Thriplow Neighbourhood Plan notes in paragraph 2.30 that a housing needs survey undertaken in 2018 identified 22 households in need of affordable housing with a local connection to Thriplow parish. The positive allocation of suitable and available sites to help address this housing need would contribute towards the delivery of sustainable growth.

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 annual delivery rates 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 where sustainable growth can be delivered

As requested in MPM Properties (TH) Ltd and Thriplow Farms Ltd’s representations to Section 6.2: Rest of Rural Area, the Grain store site as Lodge Road Thriplow should be allocated in the emerging GCLP for residential development.