Comment

Greater Cambridge Local Plan Preferred Options

Representation ID: 57890

Received: 12/12/2021

Respondent: Martin Grant Homes

Agent: Savills

Representation Summary:

Land north of Cambourne, Knapwell (HELAA site 40114)

There is significant potential to add to the range of uses at Cambourne in a highly sustainable way, including new leisure, employment and homes, enabling more residents to both live and work there and thereby increasing self-containment and correspondingly reducing the need to travel. Our evidence shows that, by increasing self-containment and extending existing and proposed public transport, there is the opportunity to add significant levels of employment and housing to the north of Cambourne without impacting on overall levels of car-based journeys. We also consider that the red scores in the HELAA can be mitigated and addressed satisfactorily.

Full text:

Policy S/CB: Cambourne

3.1. Cambourne is a location where housing and employment already exist and where there is supporting community infrastructure in terms of shops, schools and other services. There is, however, significant potential to add to the range of uses located at Cambourne in a highly sustainable way, including new leisure, employment and homes enabling more residents to both live and work there and thereby increasing self-containment and correspondingly reducing the need to travel. Our evidence shows that, by increasing self-containment and extending existing and proposed public transport, there is the opportunity to add significant levels of employment and housing to the north of Cambourne without impacting on overall levels of car-based journeys .
3.2. We note that whilst there was no specific consultation on the issue of development at Cambourne in the First Conversation consultation, the Councils did ask for views about focusing development on transport corridors. In the consultation response to the First Conversation there was broad support for this approach, and for focusing development at public transport nodes.
3.3. Further to this, development around Cambourne formed a core part of ‘Strategic Spatial Option 8: Growth around Transport Nodes: Western Cluster’. Stakeholder workshops identified the benefits of matching jobs and homes with planned infrastructure around the EWR station and Greater Cambridge Partnership Cambourne to Cambridge Public Transport Project.
3.4. The First Proposals consultation document acknowledges that EWR means that Cambourne will be one of the best-connected places in the region, although the location of the new station is ‘yet to be resolved’. Nevertheless, we know from the EWR 2021 consultation that the preferred option for the route and a station to serve Cambourne is on MGH land, to the north of the A428. EWR has said, in support of this emerging preference (Route Alignment 9), “we believe that there is more potential for new homes and communities in the area (particularly for North Cambourne compared to Cambourne South)” and identify that the route can support more jobs and prosperity, as well as being cost-effective.
3.5. Savills and MGH have actively engaged in the EWR Consultation that took place earlier in 2021. We have shared with the EWR team our masterplans and details of the optioned land, which was previously submitted in the Call for Sites. We have also confirmed that we understand there is a need to re-appraise the masterplans in light of the preferred option to position a station at North Cambourne.
3.6. We have confirmed to the EWR team that MGH is fully supportive of the proposed alignment, due to the benefits for Cambourne, as acknowledged in the First Proposals consultation. In addition, MGH is keen to continue to engage actively with EWR as well as participate in wider stakeholder discussions. We understand that the preferred option may require a four-track width, as a passing loop, to accommodate freight if needed, rather than just two tracks, in part of the section north of the A428. Again, this has been considered in our emerging illustrative masterplan, with a sufficient width of rail corridor to accommodate this ambition.
The expected delivery of East West Rail and its relationship with Cambourne

3.7. The EWR project, and its preferred alignment, is a significant bonus to this already highly sustainable location. We suggest that the earlier delivery of this new mixed-use community should not be delayed pending the construction of the railway line and station, but rather that it’s delivery should be facilitated sooner, recognising the major benefits the railway and station will bring, in due course, to a settlement that is already well connected, whilst also being capable of high levels of self-containment.
3.8. The AECOM supplement paper that forms part of the evidence base states that the Councils’ assumptions in the Preferred Options trajectory result in delivery at Cambourne starting in 2032/33. This reflects the anticipated date for the new station at Cambourne to be opened as part of EWR and that the Councils will either not require a further supplementary guidance document after an allocation is made in the new Local Plan or that this will be prepared alongside the final stages of the Local Plan and adopted around the same time. This will be important in helping to speed up delivery, and allows proper consideration to be given to the component parts as the Plan evolves through to the submission stage.
3.9. EWR should be operational from 2030 onwards which will increase demand for housing in this location with good accessibility to employment and services in Cambridge, Milton Keynes and Bedford; and by this point Cambourne will be well-established as a new town and will begin to be a market in its own right (rather than ‘overspill’ for Cambridge). Combining the trajectories from Bourn Airfield, Cambourne West (due to be completed in 2037/38) the peak delivery is set to be 550 dwellings in 2036/37 from three strategic sites along the A428 / EWR corridor.

The MGH Vision for Cambourne

3.10. It is very clear that the Greater Cambridge combined authorities acknowledge that Cambourne can develop into a more substantial and self-contained town with a more vibrant centre (p.23 of the ‘First Proposals’ consultation document). MGH supports the overall aims for an expanded Cambourne to provide sufficient critical mass to allow it to perform the following role as a:
• Well-connected place through high quality public transport, cycling and walking facilities;
• South Cambridgeshire town for the 21st century which achieves carbon net zero targets;
• growing employment centre to provide local opportunities for its residents and nearby communities; and
• place that meets the day to day needs of its residents.
3.11. MGH considers that there is a fundamental opportunity to the north of Cambourne to create a scale of growth that allows for, what the First Proposals consultation refers to specifically as a ‘more substantial town with a more fully developed and lively centre’, with a sufficient socio-economic and physical mass to allow it to self-support required job and housing provision, as well as reduce the effects of travel by private car. It will also reduce development pressure on the Cambridge Green Belt and the associated need to demonstrate exceptional circumstances for development there.
3.12. The Transport Appraisal, prepared by i-Transport, that is appended to this representation makes clear that development of land north of Cambourne is not reliant on any new rail corridor or bus corridor coming forward. However, the site provides demonstrable opportunity for creation of a new multi-modal transport hub in the event that EWR and/or Cambridge to Cambourne come forward.
3.13. The site is well located to promote a new transport hub and can offer direct connections from the A428 and can facilitate a future, new, North Cambourne railway station, as part of East-West Rail should this come forward. Similarly the site can support C2C, should it come forward, as well as Park & Ride.
3.14. A summary of the potential transport interventions that may benefit the site are outlined in the i-Transport report that accompanies this representation.
3.15. MGH sees the 1,950 homes identified in Policy S/CB as the initial stage of a more significant opportunity, given that there is every opportunity for raising the numbers at Cambourne, building on the points we make in this representation.
3.16. The timescale for the Plan is currently proposed to 2041 but, as we emphasised at paragraph 2.10, strategic policies are encouraged by the NPPF to look at longer timescales for delivery. This extension of time is necessary both to meet the requirements of the NPPF and to properly consider how strategic growth can take place in a coordinated way alongside the substantial investment in infrastructure that is planned for the area. The recent ‘Building Better Building Beautiful Commission’ report endorses the joint authorities approach informed by the 2050 Peterborough and Cambridgeshire plan. The Commission also envisage a strategic plan of some 30 years as the necessary requirement to deliver place stewardship and ensure integrated control.
3.17. MGH support the preferred strategy, which proposes densification of Cambridge, including the non-GB edge, and expanding a growth area around transport nodes (in particular around Cambourne) with limited development in the villages, whilst recognising that some villages are located sustainably and able to accommodate some growth.
3.18. Given the preferred strategy set out in the consultation, and that Cambourne is recognised as a suitable location with existing great links, and proposed improvements in infrastructure, the emerging Plan should evaluate how the settlement should grow to become a truly vibrant and highly sustainable community.
3.19. MGH’s answer is to propose a wide mix of land use, including leisure and cultural facilities, together with a mix of new housing typologies (to balance the current homogenous suburban offering at Cambourne) and a choice of schools. These built components would be set within extensive Green Infrastructure, woodland and green spaces, with development guided by a code for great placemaking.
3.20. The aspirations of existing Cambourne residents are also really important, in terms of access to jobs / leisure / community and nature, and there seems to be a high level of optimism about how EWR can allow these to begin, and for the best opportunities to be brought forward.
3.21. Work MGH has undertaken with the Town Council shows that many people support an extension of Cambourne to the north, particularly if it delivers on better shopping, a swimming pool (and potentially cinema, and other leisure uses). That scale of ambition all helps the sustainability picture too, and gets Cambourne towards being the ‘proper town’ that the consultation document alludes to
3.22. MGH is therefore seeking allocation of its land interest at North Cambourne as part of this emerging Local Plan, in recognition of the long-term opportunity here to deliver sustainable development.
Greater Cambridge HELAA Report – Site Reference 40114.
3.23. The scoring and weighting in the HELAA Report, and in relation to land North of Cambourne (Site Ref 40114) is necessarily high level. However, it also indicates some results that seem, on the face of it, to be unsubstantiated, especially in the context of the large area of land controlled by MGH and the significant opportunities this provides for landscape measures, biodiversity net gain and wider benefits that can be delivered within this wider space.
3.24. The North Cambourne site is identified in the HELAA Report both as ‘available’ and ‘achievable’, with which we concur. However, the ‘suitability’ overall score is ‘red’, and also contains some red scores on technical matters; namely Landscape & Townscape, Biodiversity & Geodiversity; Historic Environment and Archaeology.
3.25. Based on the Methodology and Assessment Criteria, the overall concluding red score on suitability indicates that ‘The site does not offer a suitable location for development for the proposed use and/or there are known significant constraints or impacts which cannot be mitigated’.
3.26. Fundamentally MGH does not consider the HELAA Report to represent an accurate analysis of the land at North Cambourne. By their nature, developments on greenfield sites will involve the loss of existing open land (often of high agricultural land value in the Cambridgeshire context) and associated impacts on landscape that are negative and unavoidable. However, the assessment also needs to take account of the wider prospects for mitigation, including extensive buffer planting and off-sets, and for biodiversity net gain, as well as the wider balance of benefits and improvements in the context of the Local Plan strategies for sustainable growth. We have developed these points further in our consideration of the Sustainability Appraisal in Section 5, and our vision document demonstrates the overall benefits.
3.27. Looking in more detail, the Methodology for the Assessment Criteria of Suitability indicates that for Landscape and Townscape the red score is associated with development that would have a ‘significant negative impact which cannot be mitigated’ and for Biodiversity where the development would have ‘a detrimental impact on designated sites, or those with a regional or local protection which cannot be reasonably mitigated or compensated as appropriate’. For Historic Environment the red score is considered to apply where development of the site would ‘cause substantial harm, or severe of significant “Less than substantial harm” to a designated heritage asset or the setting of a designated heritage asset which cannot be reasonably mitigated.’ For Archaeology the red score indicates ‘Known archaeology of significance which could not be mitigated through design or conditions.’
3.28. In the following sections we tackle these main ‘red’ flags, which were weighed against the suitability of the site;
3.29. Landscape & Townscape – the HELAA identifies that the site lies within the National Character area of the Bedfordshire & Cambridgeshire Claylands, and the Local Character area of the Western Claylands. The assessment comments that there are wide, local views and amenity views due to the open nature of the fields and low-lying boundary hedgerows. The effect of large-scale development is seen as having a significant adverse effect on the landscape as a resource in its own right and effects on views and visual amenity.
3.30. The Chris Blandford Associates supplementary report within the Council’s evidence base suggests that the provision of appropriate strategic landscape mitigation and enhancement measures for integrating the extension of Cambourne into the surrounding countryside would be a key policy consideration for the new Local Plan. Such an approach, it suggests, is likely to be based on the following principles;
• Maintain strategic countryside gaps to protect the distinct character and separate identity of the rural villages;
• Create a strong landscape structure to screen/soften the edges of built development as experienced in views across adjacent landscape types;
• Strengthen the character of linear landscape features to create biodiverse and accessible green corridors connecting new settlements to the surrounding countryside (informed by the findings of the Green Infrastructure Study); and
• Ensuring high quality and distinctive design that is responsive to local character and creates a strong sense of place through sustainable building/urban design and appropriate landscaping and green infrastructure provision.
3.31. Our representation is supported by a Landscape & Visual Assessment (LVA), prepared by Cooper Landscape Planning. This assesses our emerging illustrative masterplan in the context of the landscape character areas, key views and associated receptors. The LVA concludes that it is obvious that development will change the local landscape character of any site, and North Cambourne is no different. Nevertheless, the design approach adopted of retaining an open landscape, with development enclosed behind strong woodlands is an approach that will work well in this landscape.
3.32. Accordingly, the proposal at North Cambourne has been based on a positive landscape vision:
• retaining an open agricultural landscape, as well as accommodating a new settlement;
• providing a series of significantly strong woodland to create the framework for development; and
• forward planning the eastern area to allow for the growth of planting fer development commencing in the west.
3.33. The extended North Cambourne proposal has been modelled to provide an accurate representation of how the housing blocks would look from key viewpoints. This includes the location of the new woodland in the east, planted in advance and reaching up to 10-15m by the time in the western and central parcels have been built out.
3.34. The photomontages provided demonstrate that the area extended to the east will not produce unacceptable visual effects when seen from the local villages of Elsworth and Knapwell.
3.35. Overall the view is that the proposals will become assimilated into this landscape, and the design adopted will follow the landscape character principles set out in guidance.
3.36. Biodiversity & Geodiversity – the HELAA confirms the location of an SSSI, Wildlife Site and Ancient Woodland within the area of MGH land interest. The summary states that the development would have adverse impact on designated sites, or those with a regional or local protection ‘which cannot be reasonably be mitigated or compensated as appropriate’.
3.37. However, the Biodiversity & Green Spaces Topic Paper states that the Western Gateway Multi-Functional GI corridors provide opportunities to improve biodiversity by expanding and joining up the existing woodland, hedgerow and grassland habitat network.
3.38. The objectives identified in the Topic Paper will be delivered through an extensive Green and Blue Infrastructure Strategy that will include new woodland planting, natural regeneration, hedgerow extension and management, and habitat restoration. The strategy also requires that opportunities for biodiversity offsets from EWR are sought. Other suggested measures include;
• ensuring negative impacts from access and recreational pressure on sensitive ecological sites (Eversden and Wimpole SAC, and woodland SSSIs) are minimised, by providing additional GI sites for recreation, promoting alternative or new access routes, and educating visitors on the value of conserving habitats.
• improving access throughout the area for people (where it will not cause detrimental impact on ecological sites - as above) through opportunities associated with East West Rail as well as along river corridors.
3.39. In the vision document and illustrative masterplan we identify how we can capitalise on these opportunities, and identify ways to make suitable and substantial net gains. The Green Infrastructure being proposed is in excess of 60% of the land interest (around 400 acres). This point is also expanded upon in following sections.
3.40. Heritage – the presence of a listed asset, under ‘Historic Environment’, and crop marks under ‘Archaeology’, have resulted in views in the HELAA that development would cause substantial harm, or the more severe end of ‘less than substantial harm’. Again this seems to take no account of the ability to reflect on setting, historic landscape, buffers and mitigation, plus the need to consider significant public benefits that would accrue.
3.41. The Chris Blandford Associates paper assessing the blended approach comments that “The concentration of development at Cambourne, the NEC and Airport, should enable the management of risk through appropriate design responses e.g. height, massing, landscape etc. The Cambourne area poses lower inherent risks with regard to Cambridge and designated heritage assets than many other sites.”
3.42. The Savills Heritage Team has reviewed the more detailed aspects of this topic. The known heritage assets sensitive to any development within the site includes the two Grade II listed structures at New Inn Farm, and potentially non-designated heritage assets at other historic farmsteads within, and immediately adjacent to, the site.
3.43. Beyond this initial desk-top analysis, there has been no fieldwork or on-site investigation of the indicated cropmark and earthwork features within the site.
3.44. As part of the ongoing planning process, a staged programme of archaeological fieldwork and supporting studies will be undertaken to increase the understanding of heritage assets on the site. This would include further Desk-Based Assessment and geophysical surveying, and focused evaluation trenching by way of an agreed Written Scheme of Investigation, as necessary. These methods will provide a greater understanding of the extent and type of features that exist. The results of this additional assessment would further inform the level of significance of these remains and any further mitigation that may be necessary.
3.45. A sensitively designed layout of any proposed development, which includes off-setting development and/or the appropriate use of intervening landscaping would be implemented to mitigate potentially adverse harm to the setting of the designated and non-designated heritage assets within or adjacent to the site. Notably, avoiding built development adjacent to the listed New Inn Farmhouse and barns would preserve their setting and minimise harm. Development would therefore not give rise to any direct harm to the fabric of listed buildings. In addition, a scheme which provides a degree of separation of any new development and incorporates layered tree planting/vegetation buffers and open-ness around New Inn Farmhouse and barns would provide reasonable mitigation. With this combination of measures any substantial or significant ‘less than substantial’ harm to the setting/significance of the designated heritage assets would be avoided.
3.46. In considering any non-designated built heritage assets, their identification and assessment would be undertaken, and the significance they possess and/or the contribution of their setting to their significance would be understood. A design scheme which recognises their setting and responds to it by safeguarding where necessary and appropriate off-sets would mitigate any harm resulting from development.
3.47. We also notice that some other sites that are indicated as being ‘located in a landscape of cropmarks of late prehistoric and Roman settlement and associated activity’ are scored as amber. This scoring appears to acknowledge the potential for mitigation to be implementation in a way that is consistent with the approach described above. The Heritage and Archaeology HELAA analysis for North Cambourne should therefore be revised accordingly.
3.48. Other elements of the HELAA which scored as amber for North Cambourne included; Adopted Development Plan Policies, Flood Risk, Site Access, Transport & Roads, Noise, Vibration, Air Quality and Ground Conditions (including the loss of Grade 2 Agricultural Land). However, the HELAA recognises the potential to overcome and mitigate for concerns in these areas, subject to detailed design, conditions and controls. The illustrative masterplan contained in the vision document provides an initial assessment of the range of measures that would be incorporated in the scheme at North Cambourne to ensure a comprehensive mitigation strategy is implemented. The site is of sufficient scale to accommodate these mitigation strategies as well as secure a scale of development consistent with the sustainable new community that MGH proposes.