Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57502

Received: 10/12/2021

Respondent: Cambridgeshire County Council (as landowner)

Agent: Carter Jonas

Representation Summary:

Summary: Hawthorn Community Centre, Haviland Way, Cambridge (HELAA site 40166); Bellersby College, Arbury Road, Cambridge (HELAA site 40172); Cambridge Professional Development Centre (New site); Horizon Resource Centre (New site); Land at Chandos Farm adjacent to Babraham Park & Ride (HELAA site 40141); Newbury Farm, Worts Causeway, Cambridge (HELAA site 40139); Mansel Farm, Oakington (HELAA site 40455); Land at Gebe and Fen Farm, Twenty Pence Road, Cottenham (HELAA site 40176); Land west of Cottenham Road, Histon (HELAA site 40193); Land east of Glebe Way, Histon (HELAA site 40192); Land at Robinson Far, Cambridge Road, Sawston (HELAA site 40146); Land to north of Cardyke Road, Waterbeach (HELAA site 40183); Land at Belsar Farm, Sponge Drove, Willingham (HELAA site 40179); Land at Tostock Farm, Cambridge Road, Melbourn (HELAA site 40199); and, Land at Herods Farm, High Street, Foxton (HELAA site 40148)

Request: assumptions about faster housing delivery rates for Northstowe and Waterbeach are deleted from the development strategy.

Request: realistic assumptions about delivery are applied for North East Cambridge and Cambridge East.

Request: 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 larger allocations.

Request: that small scale housing allocations should be made in the more sustainable villages within the rest of the rural area.

Full text:

Cambridgeshire County Council as landowner has interests in land across the GCLP area and has promoted a number of sites for development within Cambridge, the edge of the city, and across the rural area.

Cambridgeshire County Council as landowner supports the focusing of development on Cambridge City and the city hinterland. Paragraph 120(d) of the NPPF expects planning policies to promote and support the development of under-utilised land and buildings and to use sites more effectively including for housing. The County Council is promoting a number of sites within Cambridge City: Hawthorn Community Centre (ref 40166) and Bellersby College (ref 40172), and the new submissions of the Cambridge Professional Development Centre and Horizon Resource Centre sites. These are all existing sustainably located brownfield sites which are either currently available or can be made available within the plan period.

Land at Chandos Farm adjacent to Babraham Park and Ride (ref 40141) is similarly an underutilised mixed-use site that could be more effectively developed as employment land.

Cambridgeshire County Council as landowner supports limited Greenbelt release in edge-of-city locations. The site at Newbury Farm, Worts Causeway (ref 40139) is situated between the Babraham Park and Ride to the east, an already committed housing development to the west, and a proposed expansion of the Biomedical Campus to the south. This site could be developed to provide new housing, including key worker housing, and green infrastructure to link with these existing and planned growth areas.

However, the overall development strategy set out in the emerging GCLP 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 are 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 predicts high average annual housing delivery rates for the new settlements; Northstowe and Waterbeach are predicted to deliver 250 dwellings per annum, and Camboure West and Bourne 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 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 many villages, which contain a good range of services and facilities and are 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. Cambridgeshire County Council as landowner is 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.

Cambridge County Council supports the allocation of Mansel Farm, Oakington (reference 40455). Oakington contains a good range of services and facilities, and the site is highly accessible to the Cambridge Guided Busway. This is reviewed further in representations to policy S/RRA/MF.

The County has sought to promote additional sites for development at locations in Cottenham (ref 40176), Histon (refs 40193 and 40192), Sawston (ref 40146), Waterbeach (ref 40183), Willingham (ref 40179), Melbourn (ref 40199) and Foxton (ref 40148). All are ranked in the current Local Plan as either Rural Centres or Minor Rural Centres, and Foxton (currently a Group Village) has a train station and is potentially to become a rural travel hub. All of these villages contain a good range of services and facilities, including schools, shops and public transport links. Several of the sites benefit from close proximity to rail stations with links to central Cambridge and London.

South Cambridgeshire District Council's 'Housing Statistical Information Leaflet' (December 2019) identified 1,222 applicants on the housing register, including 88 in urgent need (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 further allocations in the larger villages of the Plan area. The sites promoted by the County Council 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 within the rest of the rural area, 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 housing in those villages which would not be met via other means.

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, 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 housing in those villages.