OBJECT

Dudley Developments is promoting land north of Cherry Hinton Caravan & Motorhome Club off Limekiln Road, Cambridge for residential development, and in representations has requested that the site is allocated in emerging GCLP. These representations to Policy S/DS are focussed on the preferred development strategy for the edge of Cambridge, and specifically the decision to not release additional land from the Green Belt at sustainable locations on the edge of Cambridge.

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 development by Dudley Developments at land north of Cherry Hinton Caravan & Motorhome Club off Limekiln Road in Cambridge is located within the Green Belt, and in these representations it is requested that the site is 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 cost of buying and renting housing in Greater Cambridge is high, and the affordability ratio is high too. The Housing Needs of Specific Groups Report (GL Hearn October 2021) provides further information on affordability and affordable housing needs. Table 42 of the GL Hearn Report identifies an affordable housing need of 199 dwellings per annum for Cambridge and 105 dwellings per annum for South Cambridgeshire, which equates to a combined total of 304 affordable dwellings per annum or a total of 6,384 dwellings during the plan period from 2020 to 2041. Those that cannot afford to live in Greater Cambridge will need to live elsewhere and undertake longer distance commuting to access their job, and if as is likely those journeys are undertaken by car this would add to traffic congestion and air pollution. 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. The site at land off Limekiln Road in Cambridge is in a sustainable location for development in transport terms. It is accessible to Addenbrookes Hospital, Cambridge Biomedical Campus, Peterhouse Technology Park and to Cambridge. Cherry Hinton contains a very good range of services and facilities.

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. The promoted development at land off Limekiln Road in Cambridge is accessible by sustainable modes of transport. Queen Edith's Way and Cherry Hinton Road are on bus routes. The Greater Cambridge Partnership’s Making Connections project identifies Cherry Hinton as a key location on a bus corridor, with improved bus links to Addenbrooke’s and Cambridge Station. There is a dedicated cycle path on Cherry Hinton Road. The Greater Cambridge Partnership’s proposed Fulbourn Greenway project, which includes new dedicated walking and cycling routes and improvements, passes through Cherry Hinton. Therefore, the release of the land off Limekiln Road in Cambridge from the Green Belt 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 2.3: Edge of Cambridge and the HELAA Site Assessments (for Site Ref. 40528), the land off Limekiln Road in Cambridge makes a limited contribution to openness and the purposes for including land within the Green Belt, and does not contribute towards the wider landscape of Cambridge, and should be released from the Green Belt in emerging GCLP.

There are two other paragraphs in the NPPF that suggest additional allocations should be made in on the edge of Cambridge. 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. 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.

The site at land off Limekiln Road in Cambridge is in a sustainable location for development in transport terms. It is accessible to Addenbrookes Hospital, Cambridge Biomedical Campus, Peterhouse Technology Park and to Cambridge. There are primary and secondary schools in the local area and elsewhere in Cambridge. Cherry Hinton contains a range of services and facilities, including convenience stores, health facilities including doctor’s surgeries and dentists, public houses, and restaurants. The promoted development would support the existing services and facilities in Cherry Hinton. As set out above, the site is highly accessible by walking, cycling and bus services. Therefore, the promoted development at land off Limekiln Road in Cambridge is accessible by a range of sustainable modes of transport and is accessible to an excellent range of services and facilities and to employment opportunities. It would be consistent with national policy to direct additional development to this site.

As highlighted above, there is a significant need for affordable housing in Cambridge and across Greater Cambridge. There are limited previously developed land opportunities within and on the edge of Cambridge that have not already been identified. It is considered that all opportunities should be identified to meet housing and affordable housing needs, including small Green Belt sites on the edge of Cambridge and well-related to existing neighbourhoods where no significant constraints to development exist. The smaller sites in the Green Belt are always overlooked for potential release to meet housing and affordable housing needs. The promoted development by Dudley Developments at land off Limekiln Road in Cambridge would include housing and affordable housing.

For all these reasons, small scale housing allocations should be made in the more sustainable locations on the edge of Cambridge, including small sites within the Green Belt.

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 locations on the edge of Cambridge including land off Limekiln Road in Cambridge which is close to Cherry Hinton, because it is accessible by sustainable modes of transport, it could support the existing services and facilities, and it would deliver affordable housing to meet identified needs in Cambridge.

As requested in Dudley Developments’ representations to Section 2.3 Edge of Cambridge, the land off Limekiln Road in Cambridge should be released from the Green Belt and allocated in emerging GCLP for residential development.